Prado Navarette v. California
134 S. Ct. 1683
| SCOTUS | 2014Background
- 911 caller reported being run off the road by a silver Ford F-150, license plate 8D94925, near Highway 1.
- CHP officers located the truck and approached; they smelled marijuana from the truck bed.
- A 30-pound marijuana seizure occurred following the traffic stop; petitioners Navarette were arrested.
- Petitioners moved to suppress evidence, arguing the stop violated the Fourth Amendment; suppression was denied.
- California Court of Appeal affirmed, finding reasonable suspicion to justify an investigative stop based on the tip.
- The Supreme Court held the stop constitutional under the totality of the circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 911 tip created reasonable suspicion | Navarette argues the tip was anonymous and unreliable. | California contends the tip bears indicia of reliability and created reasonable suspicion. | Yes; tip supported reasonable suspicion under totality of circumstances. |
| Reliability and corroboration of anonymous tips | Navarette contends lack of corroboration undermines reliability. | California maintains corroboration by license plate, location, and timing suffices. | Reliability supported by eyewitness basis, immediacy, and 911 safeguards; corroboration not strictly necessary. |
| Whether probable cause or ongoing-drunk-driving suspicion was required | Navarette asserts no ongoing crime established; stop was improper. | Navarette argues reasonable suspicion of drunk driving justified the stop. | Under totality, reasonable suspicion of drunk driving existed, justifying the stop. |
Key Cases Cited
- United States v. Cortez, 449 U. S. 411 (1981) (totality-of-circumstances test for reasonable suspicion)
- Alabama v. White, 496 U. S. 325 (1990) (reliability and corroboration of anonymous tips)
- Florida v. J. L., 529 U. S. 266 (2000) (bare-bones anonymous tip insufficient without corroboration)
- United States v. Arvizu, 534 U. S. 266 (2002) (commonsense, practical evaluation of suspicion under totality)
- Sokolow, 490 U. S. 1 (1989) (reasonable suspicion less than probable cause)