Thomas Pinner v. State of Indiana, 74 N.E.3d 226

Officers received a taxi driver tip that a black male in a blue jacket, accompanied by a black female with blonde hair, had dropped a handgun and the driver feared he might be robbed.
Officers located Thomas Pinner seated on a bench matching the description; two uniformed officers approached and asked if he had a weapon.
Pinner hesitated, appeared nervous, denied having a weapon, and officers then directed him to stand and keep his hands visible.
When Pinner stood, an officer observed the butt of a handgun in his front pocket; the gun was seized and Pinner was arrested and charged (enhanced by prior felony).
Pinner moved to suppress the gun as the fruit of an unconstitutional stop; the trial court denied suppression, the Court of Appeals reversed, and the Indiana Supreme Court granted transfer.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Pinner)	Held
Whether officers had reasonable suspicion to detain Pinner after the tip	Tip identified person with gun; officers could briefly detain to investigate and ensure public safety	Tip was a bare-bones report of a man with a gun; absent indicia of illegality or corroboration, no reasonable suspicion	No — detention violated Fourth Amendment; tip + Pinner’s nervousness insufficient
Whether the initial encounter was consensual or a seizure	Encounter was consensual until Pinner was asked to stand; detention was brief and investigative	Officers’ show of authority (two uniformed officers flanking, ordering to stand) converted encounter into a seizure	Encounter became a seizure when officers exerted control; seizure lacked reasonable suspicion
Whether nervous behavior provided reasonable suspicion	Nervousness corroborated the tip and supported suspicion of criminal activity	Nervousness alone is common and of limited weight; it does not supply reasonable suspicion	Nervous behavior was insufficient to supply reasonable suspicion
Whether a "firearm exception" permits stops on reports of guns	Public-safety concerns justify brief stops to check legality of firearms	Allowing a firearm exception would permit invasive stops on bare tips and conflict with Terry/J.L. protections	Rejected any automatic firearm exception; J.L. controls — tip must show illegality, not just identity

Terry v. Ohio, 392 U.S. 1 (investigatory stops require reasonable suspicion)
Florida v. J.L., 529 U.S. 266 (anonymous tip that person is carrying a gun, without more, insufficient for stop-and-frisk)
Pennsylvania v. Mimms, 434 U.S. 106 (not relied on for crime-specific point here; court cited Terry and related stop doctrine)
Delaware v. Prouse, 440 U.S. 648 (police may not randomly stop to check license/registration absent articulable suspicion)
Adams v. Williams, 407 U.S. 143 (reliability of tip can justify stop when indicia support illegal activity)
Alabama v. White, 496 U.S. 325 (anonymous tip with predictive information can supply reasonable suspicion)
Navarette v. California, 572 U.S. 393 (even reliable tips justify a stop only if they create reasonable suspicion of criminal activity)