State of Tennessee v. Guy Alvin Williamson
2012 Tenn. LEXIS 380
| Tenn. | 2012Background
- Officers responded to anonymous 911 tip alleging an armed party at Baxter Motel; Williamson was on the second-floor balcony near room 21.
- An officer frisked a white male and another officer frisked Williamson, yielding a .22 Rossi revolver from Williamson’s pocket.
- Suppression hearing featured Officer Nelson detailing the dispatch as “armed robbery in progress,” which he later recanted; the warrant did not reflect this description.
- Trial court denied suppression, treating the scene as a valid investigatory stop and frisk.
- Court of Criminal Appeals affirmed; this Court granted permission to appeal to review the stop’s validity based on the anonymous tip and scene facts.
- Supreme Court reverses, holding the stop and frisk lacked reasonable suspicion and the revolver should be suppressed; case dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop and frisk were supported by reasonable suspicion. | Williamson argues the anonymous tip alone, lacking reliability, did not justify detention. | State contends corroboration and circumstances at the scene justified the stop and frisk. | No; the tip lacked reliability and corroboration failed to create reasonable suspicion. |
| Whether bystander corroboration or odor/alcohol observations could cure the deficiency. | Independent corroboration from bystander would salvage reasonable suspicion. | Corroboration from bystander insufficient where tip itself is unreliable. | Insufficient corroboration to validate the stop and frisk. |
| Whether the evidence should be suppressed under the inevitable discovery or other doctrines. | If tainted, later discoveries cannot validate the tainted seizure. | Inevitable discovery would permit admission of revolver. | Inevitable discovery does not apply; tainted seizure requires suppression. |
Key Cases Cited
- Florida v. J.L., 529 U.S. 266 (2000) (anonymous tip requires reliability; no stop unless corroborated)
- Adams v. Williams, 407 U.S. 143 (1972) (face-to-face tip can support stop if reliable)
- Alabama v. White, 496 U.S. 325 (1990) (reliability and basis of knowledge test for informants)
- Ubiles, 224 F.3d 213 (3d Cir. 2000) (anonymous tip insufficient; possession of gun not per se illegal)
- Massenburg, 654 F.3d 480 (4th Cir. 2011) (anonymous tip near gunfire area not reliably linking to suspect)
- Gomes, 937 N.E.2d 13 (Mass. 2010) (anonymous tip lacking reliability not enough to stop frisk)
- Illinois v. Wardlow, 528 U.S. 119 (2000) ( Flight in high-crime area alone insufficient without basis for stop)
- United States v. J.L., 532 U.S. 266 (2000) ((note: proper citation is 529 U.S. 266) anonymous tip requires reliability for stop)