Sidney v. Com., 702 S.E.2d 124

Police received an anonymous tip that Sidney was at 1300 Patterson Street driving a tan Jeep Cherokee with warrants outstanding for arrest.
Tip described Sidney as a black male, about 5'7" to 5'9" tall; police had not previously seen him.
Officer Sloan located a matching tan Jeep Cherokee at the stated address and observed a man in the driver’s seat.
Dispatch confirmed there were outstanding warrants for Sidney’s arrest, and officers followed and stopped the vehicle when it exited the driveway.
Officer Sloan did not personally verify the warrants in a database; dispatch information was relied upon and later imputed to the officers.
A search incident to arrest yielded cocaine and marijuana.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the anonymous tip, corroborated, gave reasonable suspicion for the stop.	Sidney argues tip was unreliable and did not provide reasonable suspicion.	Commonwealth contends corroboration via dispatch warrants supplies reasonable suspicion.	Yes; stop supported by reasonable suspicion.
Whether dispatch-confirmed warrants imputes to officers and justifies the stop for driver identification.	Sidney contends no personal confirmation of warrants and tip reliance invalidates stop.	Commonwealth asserts dispatch verification imputed to officers; creates reasonable suspicion.	Dispatch-confirmed warrants imputed; stop valid for driver identification.

Florida v. J.L., 529 U.S. 266 (U.S. Supreme Court, 2000) (anonymous tips require corroboration for reasonable suspicion)
White v. United States, 496 U.S. 325 (U.S. Supreme Court, 1990) (reliability of anonymous tips depends on corroboration)
United States v. Sokolow, 490 U.S. 1 (U.S. Supreme Court, 1989) (reasonable suspicion based on totality of circumstances)
Adams v. Williams, 407 U.S. 143 (U.S. Supreme Court, 1972) (brief stop for identification reasonable on articulable facts)
Harris v. Commonwealth, 276 Va. 689 (Va. 2008) (Virginia case applying reasonable suspicion framework)
Jackson v. Commonwealth, 267 Va. 666 (Va. 2004) (anonymity and reliability in tip-based stops analyzed)
Hayes v. Florida, 470 U.S. 811 (U.S. Supreme Court, 1985) (reasonable suspicion may justify brief stop to obtain information)
Crowder v. Commonwealth, 213 Va. 151 (Va. 1972) (arrest based on warrants communicated by dispatcher can occur)
Murphy v. Commonwealth, 264 Va. 568 (Va. 2002) (standard appellate review for suppression rulings)
United States v. Hensley, 469 U.S. 221 (U.S. Supreme Court, 1985) (scope of investigative stops and purpose)