State v. Renzulli
2011 Ind. LEXIS 1097
| Ind. | 2011Background
- At 1:00 a.m. Davies called 911 describing an erratic, potentially intoxicated driver in a blue Volkswagen near a BP, providing his name and phone number.
- Officers arrived within about 90 seconds, observed a blue Volkswagen at the BP, and detained the driver, Amanda Renzulli, for investigatory purposes.
- Renzulli showed signs of intoxication; she failed three field sobriety tests and BAC was measured at 0.22%.
- Renzulli moved to suppress the evidence, arguing the stop lacked reasonable suspicion; the trial court granted the motion.
- The State appealed, arguing the tip from a concerned citizen plus corroborating circumstances supported a lawful investigatory stop.
- Indiana Supreme Court held the stop was supported by reasonable suspicion based on totality of the circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a concerned citizen tip can justify an investigatory stop | Renzulli argues the tip lacked corroboration and independent reliability. | State contends the tip, with identifying details and rapid corroboration, established reasonable suspicion. | Yes; tip plus corroboration created reasonable suspicion. |
| Whether corroboration in this case was sufficient to support the stop | No independent police corroboration beyond the tip. | Time, location, vehicle description, and immediate police response corroborated the tip. | Yes; corroboration existed and supported reasonable suspicion. |
| Whether the officer’s awareness of the driver’s gender affected reasonable suspicion | Gender misidentification undermines the basis for the stop. | Gender descriptor does not negate reasonable suspicion given other corroborating facts. | No; gender detail did not defeat reasonable suspicion. |
Key Cases Cited
- Terry v. Ohio, 379 U.S. 1 (U.S. (1968)) (establishes the framework for investigatory stops with reasonable suspicion)
- Kellems v. State, 842 N.E.2d 352 (Ind. 2006) (tips from a concerned citizen with corroboration can justify stops)
- Alabama v. White, 496 U.S. 325 (U.S. (1990)) (anonymity and reliability in tips may support reasonable suspicion when corroborated)
- Bogetti v. State, 723 N.E.2d 876 (Ind. Ct. App. 2000) (anonymous/unidentified tips can provide reasonable suspicion when corroborated by facts)
- Arvizu, 534 U.S. 266 (U.S. (2002)) (totality of the circumstances governs reasonable suspicion)
- Quirk, 842 N.E.2d 334 (Ind. 2006) (sufficiency standard for suppression rulings)