Trott v. State, 249 A.3d 833

Around 11:30 p.m. on Dec. 4, 2015, an anonymous 911 caller reported an intoxicated driver and gave vehicle color, make/model, Maryland license plate, and the specific location.
Officer Cooper arrived within 2–8 minutes, found the described silver Honda CR‑V idling in the parking lot of a liquor store, and parked 10–15 feet behind it with lights on.
Officers approached, Corporal Cooper knocked on the driver’s window, smelled a strong odor of alcohol, and Trott admitted drinking and that his license was suspended/revoked; Trott failed field sobriety tests and was arrested.
Trott moved to suppress the evidence, arguing the stop lacked reasonable suspicion because it relied solely on an anonymous tip that lacked indicia of reliability or predictive detail.
The circuit court denied the motion; Trott was convicted after an agreed statement of facts. The Court of Special Appeals certified the suppression issue to Maryland’s Court of Appeals, which affirmed the denial of suppression.

Issue	Trott's Argument	State's Argument	Held
Whether an anonymous 911 tip alleging a drunk driver provided reasonable suspicion for a Terry stop	The tip was conclusory, lacked timing or predictive details, no basis for caller’s knowledge, and officers observed no driving behavior	The tip gave specific vehicle identifiers and location, was contemporaneous via 911, and, combined with the minimal intrusion and public‑safety risk, supported reasonable suspicion	Court held the tip had sufficient indicia of reliability under the totality of the circumstances and supported a reasonable, brief investigatory stop
Whether the scope/intrusiveness of the encounter and public‑safety considerations justify the stop	The stop intruded on Trott’s Fourth Amendment interests without observed wrongdoing	Stopping an idling vehicle at a liquor store late at night is minimally intrusive; drunk driving presents imminent danger and diminished vehicular privacy	Court weighed minimal intrusion and public‑safety risk in favor of the stop; the seizure was reasonable

Navarette v. California, 572 U.S. 393 (2014) (an anonymous 911 call giving specific vehicle/location details can supply reasonable suspicion when corroborated and contemporaneous)
Florida v. J.L., 529 U.S. 266 (2000) (an anonymous tip lacking predictive detail or basis of knowledge cannot, by itself, justify a stop and frisk)
Alabama v. White, 496 U.S. 325 (1990) (an anonymous tip corroborated by police observation may provide reasonable suspicion)
Terry v. Ohio, 392 U.S. 1 (1968) (establishes investigatory stop standard requires reasonable suspicion)
United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion is a lower standard than probable cause and depends on totality of circumstances)
United States v. Arvizu, 534 U.S. 266 (2002) (reasonable suspicion may arise from a collection of facts that seem innocent separately)
Pennsylvania v. Mimms, 434 U.S. 106 (1977) (reasonableness under the Fourth Amendment turns on a balance of interests)
United States v. Knotts, 460 U.S. 276 (1983) (diminished expectation of privacy in vehicles)
Swift v. State, 393 Md. 139 (2006) (Maryland summary of stop/consensual encounter/arrest distinctions)
Cartnail v. State, 359 Md. 272 (2000) (reasonable‑suspicion inquiry requires totality of circumstances and common‑sense judgment)