State v. Gregory, 2019 Ohio 3000

Late-night 911 caller reported a black male in a tan work outfit, as a passenger in a large white work van parked near the dead-end of Harold Drive, was shooting a large handgun in the air; caller’s phone number was recorded but she refused to give her name.
Dayton PD arrived within ~7–10 minutes, drove via nearby streets, and encountered a single large white work van leaving the dead-end area; officers stopped the van.
Officer Carter opened the rear sliding door, ordered the rear passenger (Michael Gregory) out; Gregory matched the clothing description.
Officers observed a Hi-Point .40 pistol in plain view where Gregory had been seated; patdown revealed a loaded magazine and holster on Gregory, and he admitted the gun was his and that he had no CCW.
Gregory was charged with having weapons under disability and improper handling of a firearm; he pled no contest after the trial court denied his motion to suppress and appealed the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 911 tip provided sufficient reliability to justify an investigative stop under Terry	Tip was reliable: eyewitness report of recent shooting, location given, caller used 911 and her number was recorded, supporting reasonable suspicion to stop the van	Tip was effectively anonymous; recording the phone number does not transform anonymity into a reliable citizen tip; officers observed no crime or violations before the stop	Court held tip reliable (caller not truly anonymous and had first-hand, contemporaneous eyewitness knowledge); stop was supported by reasonable suspicion
Whether the stopping and subsequent search/seizure required suppression as fruit of an unlawful stop	Because the stop was lawful, later statements and evidence were not tainted and are admissible	If the initial stop was unlawful, all derivative evidence and statements should be suppressed	Court held the stop lawful, so exclusionary rule did not apply and evidence/statements were admissible

Katz v. United States, 389 U.S. 347 (court describes per se unreasonableness of warrantless searches subject to exceptions)
Terry v. Ohio, 392 U.S. 1 (investigative stop permissible based on reasonable suspicion of criminal activity)
Alabama v. White, 496 U.S. 325 (discusses reliability requirements for informant tips; close case on tip sufficiency)
Navarette v. California, 572 U.S. 393 (factors that support reliability of anonymous tips, including eyewitness knowledge, contemporaneity, and 911 tracing)
Maumee v. Weisner, 87 Ohio St.3d 295 (Ohio framework: when stop rests solely on a dispatch, state must show the facts precipitating the dispatch justified reasonable suspicion)
Florida v. J.L., 529 U.S. 266 (anonymous tip of a person carrying a gun insufficient without indicia of reliability)