25 A.3d 768
Del.2011Background
- Miller was arrested and indicted by a Delaware Superior Court Grand Jury for drug and weapons offenses; convicted of Possession with Intent to Deliver Heroin and Possession of a Firearm During the Commission of a Felony; sentenced to 10 years Level V, 8 months Level IV halfway house, and 2 years Level III probation.
- Superior Court denied Miller's motion to suppress; conviction followed a stipulated trial.
- Miller challenges the warrantless seizure as unsupported by probable cause or reasonable articulable suspicion due to reliance on an unproven, unreliable informant with limited corroboration.
- Facts show an informant with limited credibility provided detailed predictions about a drug delivery; police surveilled the area, corroborated the vehicle and timing, and Miller fled when approached; heroin and a handgun were observed in the vehicle.
- The trial court and Delaware Supreme Court held the seizure reasonable under the totality of circumstances, relying on corroborated predictive information from the informant.
- Standard of review recognizes suppression rulings as abuse of discretion, with de novo review for legal conclusions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the seizure supported by reasonable articulable suspicion based on the informant tip and corroboration? | Miller argues the informant was unreliable and not sufficiently corroborated. | State contends the tip, with specific predictions and corroboration, justified the stop. | Yes; the informant’s specific predictions and police corroboration established reasonable suspicion. |
Key Cases Cited
- Alabama v. White, 496 U.S. 325 (U.S. 1990) (informant tips with predictive information can support reasonable suspicion when corroborated)
- Florida v. J.L., 529 U.S. 266 (U.S. 2000) (anonymous tips lacking predictive information fail to establish reasonable suspicion)
- Draper v. United States, 358 U.S. 307 (U.S. 1959) (probable cause; not applicable here, but cited for informant reliability principles)
- Tatman v. State, 494 A.2d 1249 (Del. 1985) (Delaware precedent on probable cause and warrantless searches)
- Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality of the circumstances; informant reliability and corroboration considerations)
- Brown v. State, 897 A.2d 748 (Del. 2006) (informant reliability and basis of knowledge relevance in evaluating tips)