STATE OF NEW JERSEY VS. DARRYL J. HUNTER (15-02-0132, UNION COUNTY AND STATEWIDE), A-2641-15T3

At ~8:30 p.m., Elizabeth police received an anonymous tip describing a bearded Black male in a gray hooded sweatshirt and khaki pants waving a handgun on Community Lane.
Sgt. Kelly arrived within two minutes, stopped half a block away on a well-lit corner, and observed a white Pontiac pass slowly about three feet from his patrol car. He clearly saw the driver: a bearded Black male in a gray hoodie.
Kelly performed a traffic stop based on the match between the tip and his observations; the driver (Hunter) ducked after the car stopped and then opened the door when approached.
Officers saw a loaded magazine on the driver-side floor and recovered a semi-automatic handgun under the passenger seat; Hunter was arrested and later made post-Miranda statements admitting possession.
The vehicle owner (Hunter’s girlfriend) consented to a further search, which yielded suspected cocaine and a scale.
Hunter moved to suppress, arguing the stop lacked reasonable and articulable suspicion because the anonymous tip was not independently corroborated; the trial court denied the motion and Hunter pleaded guilty to weapons and terroristic-threats charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless stop of the Pontiac was supported by reasonable and articulable suspicion	Police contended the tip plus Kelly’s immediate, close-range observation of a person matching the tip near the reported location within minutes gave specific, corroborative facts justifying the stop	Hunter argued the anonymous tip alone was insufficient and police failed to independently corroborate criminal activity to justify the stop	The court affirmed: under the totality of circumstances, the close temporal and spatial proximity and the officer’s ability to observe identifying details provided reasonable and articulable suspicion for the stop

State v. Privott, 203 N.J. 16 (discusses limits of anonymous tips and need for corroboration)
State v. Gamble, 218 N.J. 412 (totality-of-circumstances test for reasonable suspicion)
State v. Maryland, 167 N.J. 471 (officer may draw reasonable inferences from observed facts)
State v. Carty, 170 N.J. 632 (automobile stop must be supported by reasonable and articulable suspicion)
Florida v. J.L., 529 U.S. 266 (anonymous tip alleging a firearm, without corroboration, insufficient for stop/search)
State v. Elders, 192 N.J. 224 (deferential appellate review of suppression findings)