United States v. Gerald Jackson, 700 F. App'x 411

Late on July 17–18, 2013, three armed men invaded a duplex in Chattanooga, tied and assaulted a resident, and fled with electronics and firearms; police arrived after 4 a.m.
A neighbor (anonymous to police but identifiable by address) reported returning home after midnight and seeing an unfamiliar beat-up silver/gray four-door sedan parked at the edge of the duplex property; it was missing its entire front bumper and had never been seen in the neighborhood before.
Officer Michael Early searched for the car for weeks. On August 6 he observed a silver sedan missing its front bumper with three Black male occupants; one occupant matched the description of a jewelry-robbery suspect (tall, dreadlocks). The vehicle briefly failed to stop, was blocked by a marked unit, and the occupants were detained.
After the stop, police found items (towel, clothes, tennis shoes) in the car; a phone was taken from Jackson and later connected to the car owner’s (Dozier) household. With Dozier’s consent, officers searched her home and garage and recovered a magazine matching a rifle found near a separate jewelry-store robbery; photos on the phone showed Jackson holding a matching rifle.
Jackson was charged in federal court, moved to suppress evidence obtained after the stop (including presence in car, shoes, statements, phone and its contents, Dozier’s statements, and garage magazine), his motion was denied, he pleaded guilty conditionally, and appealed the suppression denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the anonymous neighbor’s tip was sufficiently reliable to support investigatory police action	Jackson: unnamed neighbor’s tip lacked indicia of reliability; no proof of truthfulness or identity, so tip is unreliable without further corroboration	Government: neighbor’s information was sufficiently reliable because police knew her address and observed a concrete, particular description (bumperless silver sedan at scene)	Tip had adequate indicia of reliability (identifiable location and timely eyewitness observation); court upheld reliance on it
Whether the stop of Jackson’s car on Aug 6—19 days after the robbery—was supported by reasonable suspicion that the vehicle was linked to the July 18 home invasion	Jackson: 19-day delay and mere presence of a silver car near the scene do not establish a nexus to the robbery; no direct evidence linking car to crime	Government: totality of circumstances—specific car description (missing bumper), time/night, proximity to the crime scene, the car’s absence from neighborhood afterwards, and the likelihood robbers fled by vehicle—created reasonable suspicion	Court held the particularity of the description and other circumstances overcame the delay; stop was supported by reasonable suspicion

Florida v. J.L., 529 U.S. 266 (anonymous tip lacking indicia of reliability insufficient to justify stop)
Alabama v. White, 496 U.S. 325 (anonymous tip corroborated in key respects can support Terry stop)
Navarette v. California, 134 S. Ct. 1683 (anonymous 911 caller’s contemporaneous eyewitness report carried indicia of reliability for stop)
United States v. Long, 464 F.3d 569 (6th Cir.) (anonymous but locatable informant provided sufficient reliability to stop vehicle)
United States v. Hurst, 228 F.3d 751 (6th Cir.) (vehicle observed in proximity and time to burglary supported stop)
United States v. Marxen, 410 F.3d 326 (6th Cir.) (delay between crime and vehicle stop not dispositive where description is particular)
United States v. Patterson, 340 F.3d 368 (6th Cir.) (anonymous tips without corroboration insufficient for stops)
United States v. Cohen, 481 F.3d 896 (6th Cir.) (anonymous 911 hang-up without corroboration insufficient for stop)