State v. Pickett, 2017 Ohio 5830

At ~6:40 p.m. a caller identified as "Sean" phoned 911 to report a male in a red hooded sweatshirt had fired three shots in front of a vacant house at Middlehurst Ln & Piccadilly Ave; caller gave his first name and a cell number.
Dayton officers Berger and Gresham, on routine patrol, arrived ~3–4 minutes after the call and observed Derrick Pickett in a red hooded sweatshirt about two‑tenths to one‑quarter mile from the reported intersection standing next to a white Chevrolet Tahoe with the rear driver's door open.
Body‑camera/video showed Pickett drop an object, pick it up with his left hand, reach into the vehicle, glance at the approaching cruiser, hesitate, then reach back into the vehicle; officers approached, a pat‑down was attempted, a brief struggle followed, and Pickett was handcuffed.
Officers discovered illicit drugs (not fully reflected on the record) and Pickett was indicted for possession; he moved to suppress the drugs arguing the stop was an unlawful investigatory stop.
The trial court granted the motion to suppress, finding officers lacked reasonable suspicion; the State appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable suspicion for a Terry stop based on a 911 tip plus observations	The 911 tip was from an identified citizen and corroborated by Pickett's proximity, clothing, timing, and conduct; these facts gave reasonable suspicion of recent gunfire and potential danger	The tip lacked descriptive detail; officers failed to corroborate the substance (no shots heard, location mismatch, no weapon observed); officers should have used less intrusive means before detaining	Court (majority): Officers had reasonable suspicion; stop was lawful and suppression order reversed

Terry v. Ohio, 392 U.S. 1 (1968) (establishes investigatory stop and reasonable‑suspicion standard)
Florida v. J.L., 529 U.S. 266 (2000) (anonymous, uncorroborated tip describing only clothing is insufficient for stop)
City of Maumee v. Weisner, 87 Ohio St.3d 295 (1999) (police reliance solely on a dispatch requires showing the facts precipitating the dispatch justified reasonable suspicion)
United States v. Terry‑Crespo, 356 F.3d 1170 (9th Cir. 2004) (911 calls reporting ongoing emergencies carry greater reliability and may provide reasonable suspicion)
Florida v. Royer, 460 U.S. 491 (1983) (investigative methods should be the least intrusive means reasonably available)
State v. Shepherd, 122 Ohio App.3d 358 (1997) (discusses reasonable suspicion and citizen informant reliability)