State of Minnesota v. Darren Gregory Melges, A16-539

In Dec. 2015, J.P. (identified by name/address) called 911 twice reporting Darren Melges at his rural property after Melges had been denied permission to search for a deer; J.P. said Melges was a "meth head," might be armed, had been seen shooting from the road, and drove a blue Ford pickup with an ATV.
Deputy located a truck matching the description; no traffic violations observed. Deputy conducted a felony stop, performed a pat-down, and detained Melges.
During the stop Melges admitted a rifle was in the truck; officers found an uncased, loaded rifle and later discovered marijuana and drug paraphernalia; Melges had a prior felony violent conviction.
State charged Melges with firearm possession by a prohibited person and drug-related counts. District court suppressed evidence and dismissed charges, concluding the stop lacked reasonable, articulable suspicion.
Appellate court reviewed de novo, held J.P.’s identified tip had sufficient indicia of reliability and that, under the totality of the circumstances, the deputy had reasonable suspicion to stop Melges; reversed suppression and remand for further proceedings on whether a felony stop was justified.

Issue	State's Argument	Melges's Argument	Held
Whether deputy had reasonable, articulable suspicion to stop Melges	J.P. was an identified, locatable informant who reported Melges reentered property after being denied permission and suspected shooting from road; tip plus vehicle description created reasonable suspicion of trespass/hunting from road	J.P.’s report described lawful conduct (retrieving wounded game) and lacked evidence owner had "personally notified" defendant not to return; tip was speculation, not reliable basis for stop	Reversed suppression: identified informant + details (vehicle description, return after denial, allegation of shooting) provided sufficient indicia of reliability and reasonable suspicion to stop
Whether facts justified a felony stop (use of drawn firearms and detained movement)	State urged stop for investigating trespass and safety given informant’s report he might be armed	Melges argued no probable cause supporting a more intrusive ‘‘felony stop’’	Remanded to district court to make findings on whether higher showing for a felony stop was met (higher standard than investigatory stop)

Terry v. Ohio, 392 U.S. 1 (1968) (Terry stop standard permits brief investigatory stops based on reasonable, articulable suspicion)
United States v. Sokolow, 490 U.S. 1 (1989) (reasonable-suspicion inquiry under totality of the circumstances)
Navarette v. California, 134 S. Ct. 1683 (2014) (an anonymous or nonconclusive tip can justify a stop if it creates reasonable suspicion)
City of Minnetonka v. Shepherd, 420 N.W.2d 887 (Minn. 1988) (factors for informant-tip-based traffic stops: identifiability and factual basis for alleged law violation)
Playle v. Comm’r of Pub. Safety, 439 N.W.2d 747 (Minn. App. 1989) (reliability enhanced when informant provides means for identification/ accountability)
Jobe v. Comm’r of Pub. Safety, 609 N.W.2d 919 (Minn. App. 2000) (informant tips may support investigatory stops if they show indicia of reliability)
State v. Flowers, 734 N.W.2d 239 (Minn. 2007) (felony/immobilization stop requires a higher justification than a Terry stop)