People of Michigan v. James Michael Stapley, 331413

Defendant James Michael Stapley was convicted after a bench trial of carrying a concealed weapon (MCL 750.227) and operating a vehicle with a high blood alcohol content (MCL 257.625(1)(c)), and sentenced to concurrent 365-day jail terms.
Before trial, Stapley moved to suppress evidence, arguing the traffic stop was unlawful for lack of reasonable suspicion; the issue was preserved for appeal.
Police stopped Stapley’s vehicle after receiving dispatcher reports: AT&T employees allegedly identified a visibly intoxicated driver and described his vehicle and license plate; additional motorists reported erratic driving by a vehicle matching that description.
The officer who executed the stop relied on dispatcher information and testified he would not have stopped the car if the reported license plate had not matched.
Officers corroborated vehicle and plate information and linked the identity/home address before the stop; AT&T employees were not named on the radio but were not truly anonymous and their accounts were consistent.
The trial court denied suppression; the Court of Appeals reviewed the legal questions de novo and factual findings for clear error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable, articulable suspicion to stop Stapley’s vehicle based on dispatcher/informant reports	The reports (AT&T employees + motorists) were sufficiently reliable and corroborated to give officers reasonable suspicion of intoxicated/erratic driving	The officers lacked firsthand observation of drinking or erratic driving; dispatcher tips were unreliable/anonymous, so the stop was unlawful and evidence should be suppressed	Court held the totality of circumstances (dispatcher relay of nonanonymous, corroborated reports and plate match) provided reasonable suspicion to justify the investigatory stop; suppression denied

Peterman v. Dep’t of Natural Resources, 446 Mich. 177 (preservation of suppression issue)
People v. Barbarich, 291 Mich. App. 468 (reasonable-suspicion/Terry-stop standard)
People v. Tanner, 496 Mich. 199 (standard of review for suppression rulings)
People v. Kurylczyk, 443 Mich. 289 (clear-error definition)
People v. LoCicero (After Remand), 453 Mich. 496 (reasonable suspicion for stops of moving vehicles)
People v. Oliver, 464 Mich. 184 (viewing circumstances as law enforcement would)
People v. Tooks, 403 Mich. 568 (three-factor test for informant-tip reliability)
People v. Estabrooks, 175 Mich. App. 532 (stop need not be based on knowledge of exact crime)
Michigan Dep’t of State Police v. Sitz, 496 U.S. 444 (state interest in preventing drunk driving)
People v. Christie, 206 Mich. App. 304 (erratic driving can create reasonable suspicion of intoxication)