People v. Sanders, 986 N.E.2d 114

Woman flags patrol officer and reports a man placed a machine gun in a Chrysler (color: gold/brown) driven by a man described as short black male, 30–35, wearing a red coat and blue pants.
Officer Dolan locates the described car about a mile away and stops it at a light on Halsted Street, with defendant driving.
Defendant exits the car after officers position around it; a machine gun is recovered from the backseat during the stop.
Dolan did not have a warrant or observe traffic violations at the time of the stop.
Defendant was later convicted as armed habitual criminal; the stop and suppression ruling are challenged on Fourth Amendment grounds via plain error and ineffective assistance theories.
Court analyzes whether the 15-second in-person tip from an unidentified informant provided reasonable suspicion to justify a Terry stop.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by reasonable suspicion	Sanders: no specific articulable facts justify the stop	Sanders: tip provided reliable basis for stop given in-person tip and basis of knowledge	Yes; stop justified; suppression denied

Florida v. J.L., 529 U.S. 266 (U.S. 2000) (anonymous tip must show reliability for stop)
Alabama v. White, 496 U.S. 325 (U.S. 1990) (corroboration can elevate reliability of tips)
People v. Rhinehart, 2011 IL App (1st) 100683 (1st Dis., 2011) (face-to-face tip, reliability considerations, unidentified informant)
People v. Miller, 355 Ill. App. 3d 898 (2005) (distinction with anonymous vs. identifiable informants)
Henness v. Bagley, 644 F.3d 308 (6th Cir. 2011) (in-person tip credibility and immediacy bolster reliability)
D.P. v. State, 65 So. 3d 123 (Fla. Dist. Ct. App. 2011) (face-to-face tip details and demeanor support reasonable suspicion)
United States v. Torres, 534 F.3d 207 (3d Cir. 2008) (case-specific factors for evaluating informant tips)