Segar v. State, 937 N.E.2d 917

Op. Grigsby responded to a burglary-in-progress call based on an anonymous tip describing a white male in a dark coat.
Segar matched the generic description and was stopped and handcuffed by Grigsby, despite no evident furtive conduct.
Segar was detained and transported to the burglary detective's office; there were no warrants for his arrest.
During a patdown, Officer Frazier felt a bulge suggesting marijuana and retrieved a baggie later tested and found to contain marijuana.
Segar was charged with possession of marijuana, and a bench trial followed where a motion to suppress was denied.
Segar appealed on Fourth Amendment grounds, challenging the stop as unsupported by reasonable suspicion and arguing the marijuana evidence should have been excluded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the investigatory stop was supported by reasonable suspicion	Segar	State	Stop unsupported; reversed conviction

Arizona v. United States, — (—) (not used)
J.L. v. United States, 529 U.S. 266 (2000) (anonymous tip alone generally insufficient for reasonable suspicion)
Alabama v. White, 496 U.S. 325 (1990) (anonymous tip reliability affects suspicion required)
United States v. Arvizu, 534 U.S. 266 (2002) (totality of circumstances standard for reasonable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (2000) (minimal objective justification required beyond a hunch)
Sellmer v. State, 842 N.E.2d 358 (2006) (anonymous tip must be corroborated with some familiarity or predictive detail)
Lundquist v. State, 834 N.E.2d 1061 (2005) (objection timing and admissibility of evidence)
Berry v. State, 766 N.E.2d 805 (2002) (anonymous tip lacking reliability or predictive detail)
Washington v. State, 740 N.E.2d 1241 (2000) (anonymous tip without independent indicia of reliability not enough)
Johnson v. State, 659 N.E.2d 116 (1995) (outcome influenced by what officers knew before stop)
Brown v. State, 929 N.E.2d 204 (2010) (contemporaneous objection required to preserve suppression claim)