State v. Taylor, 2017 Ohio 139

Appellant Gabriel Taylor was convicted in Lucas County Court of Common Pleas for having a weapon while under a disability and carrying a concealed weapon; sentenced to 47 months. Appellant appealed the denial of his motion to suppress.
Police received an anonymous 911 tip reporting three black men loitering behind 437 W. Bancroft; tip said one man (wearing sunglasses) had a gun and another wore a red jacket. Tipter said the men did not live at that address and suggested drug activity.
An undercover detective in an unmarked car located a group matching the tip: one wearing glasses (Taylor) and one in red. Officers announced themselves and ordered the group to show hands. One man put a small baggie in his mouth and began chewing.
Taylor hesitated initially, failed to comply immediately with commands, then was ordered to get on the ground and to stand by a chain-link fence for a pat-down. During the pat-down, the officer felt resistance/turning and located a loaded .45 caliber handgun in Taylor’s waistband.
Trial court denied suppression, concluding the anonymous tip was corroborated by police observations (location, clothing, one subject swallowing a baggie) and that officers had reasonable suspicion to detain and perform a Terry pat-down for officer safety. The appellate court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Taylor)	Held
Whether the warrantless stop and frisk violated the Fourth Amendment	The stop/frisk was reasonable: 911 tip corroborated (location, descriptions), officers observed drug-related conduct (swallowing baggie), and had reasonable suspicion person was armed and dangerous	Anonymous tip alone insufficient; officers immediately commanded everyone on arrival creating a seizure without adequate corroboration to justify stop and pat-down	Court held the stop and frisk reasonable: tip corroborated by observations, officers developed independent reasonable suspicion (drug activity and risk of firearm), pat-down justified for officer safety

Terry v. Ohio, 392 U.S. 1 (1968) (police may conduct brief investigatory stop and limited protective frisk when reasonable suspicion exists)
Florida v. J.L., 529 U.S. 266 (2000) (anonymous tip limited to description and location insufficient alone to justify stop and frisk)
United States v. Hensley, 469 U.S. 221 (1985) (stops based on information from others depend on indicia of reliability)
Alabama v. White, 496 U.S. 325 (1990) (factors for evaluating informant tip include veracity, reliability, and basis of knowledge)
California v. Hodari D., 499 U.S. 621 (1991) (seizure requires either physical force or submission to show of authority)
United States v. Cortez, 449 U.S. 411 (1981) (totality of circumstances test for reasonable suspicion)
Map v. Ohio, 367 U.S. 643 (1961) (application of Fourth Amendment protections to states)