State v. Tahe, 35,628

A convenience-store clerk called to report a specific vehicle whose driver appeared intoxicated; the call provided a detailed vehicle description and location.
Deputy Charley located the described vehicle shortly after the call and caught up to it on the roadway.
When the deputy approached, the vehicle was stopped in the road with its left-turn signal on, apparently intending to turn into a one-way high-school exit lane.
The deputy initiated a traffic stop based on the tip and his observations; the stop developed into a DWI investigation and Defendant was convicted.
Defendant appealed, arguing the stop lacked reasonable suspicion because the anonymous tip lacked indicia of reliability and the deputy’s observations did not corroborate erratic driving.
The Court of Appeals issued a proposed summary disposition upholding the conviction and, after Defendant’s memorandum in opposition, affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an investigatory stop was supported by reasonable suspicion based on an anonymous tip describing possible drunk driving	The State: tip plus the deputy’s observations provided sufficient corroboration to justify the stop	Tahe: tip lacked indicia of reliability (no basis for caller’s belief, misidentified driver gender) and deputy’s observations did not reliably corroborate erratic driving	The Court: tip was sufficiently specific (vehicle description/location), personal observation could be inferred, and deputy’s observations supported reasonable suspicion; stop justified
Whether the deputy’s observation of intent to make an illegal turn corroborated the tip	The State: deputy’s observation of the stopped vehicle signaling into an exit-only lane was probative of careless/erratic driving	Tahe: the later change of course undermines that observation as corroboration	The Court: observation was consistent with careless/erratic driving and valid corroboration or independent basis for the stop despite the later change

State v. Lope, 343 P.3d 186 (2015) (anonymous tips describing drunk driving can justify investigatory stops when corroborated)
State v. Contreras, 79 P.3d 1111 (2003) (an eyewitness anonymous tip with detailed vehicle/location information supports detention; citizen-informant reliability presumed and strengthened by personal observation)
State ex rel. Taxation & Revenue Dep’t v. Van Ruiten, 760 P.2d 1302 (1988) (unidentified caller’s detailed description of an apparently intoxicated driver provided adequate basis for investigatory stop)
State v. Anaya, 217 P.3d 586 (2009) (reasonable suspicion does not require an officer to actually observe illegal activity)
State v. Brennan, 970 P.2d 161 (1998) (officer may have reasonable suspicion of careless driving even if the defendant is not ultimately convicted of that offense)