United States v. Reginald Edwards
2014 U.S. App. LEXIS 14817
| 9th Cir. | 2014Background
- Anonymous 911 caller reported a "young black male" shooting at cars at West Blvd & Hyde Park Blvd; caller described height (~5'7"–5'9"), age (~19–20), clothing (black shirt, gray khaki pants), said shooter had a black handgun and entered a nearby liquor store; call lasted ~5 minutes.
- Officers received the dispatch, arrived within minutes, and observed Reginald Edwards walking ~75 feet from the liquor store; Edwards was Black, 5'11", 26 years old, wearing a black long-sleeve shirt and gray pants.
- Four officers approached with guns drawn, ordered Edwards and a nearby Hispanic male to kneel; Edwards was handcuffed, patted down, and a .22-caliber revolver fell from his pant leg.
- Edwards was charged under 18 U.S.C. § 922(g)(1); he moved to suppress evidence from the stop. The district court denied suppression under Terry doctrine; Edwards entered a conditional guilty plea and appealed.
- The Ninth Circuit reviewed de novo whether the stop was an investigatory Terry stop or an arrest, and whether officers had reasonable suspicion based on the anonymous 911 call.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the officers' tactics converted the investigatory stop into a de facto arrest requiring probable cause | Edwards: pointing guns, kneeling, handcuffing and pat-down were sufficiently intrusive to be an arrest | Govt: aggressive tactics were justified by report of a recent shooting and safety concerns; restraint was proportional and temporary | Court: Not an arrest; intrusive methods permissible given risk and recent violent report (investigatory stop upheld) |
| Whether officers had reasonable suspicion to stop Edwards based on an anonymous 911 call | Edwards: anonymous tip lacked reliability and predictive information (citing J.L.) | Govt: anonymous 911 call reported ongoing, dangerous conduct by an eyewitness with descriptive details; call had indicia of reliability (Navarette, Terry-Crespo) | Court: Reasonable suspicion existed; anonymous 911 exhibited sufficient indicia of reliability to justify stop |
| Whether features of the 911 call (eyewitness, contemporaneous, excited utterance) made it reliable enough | Edwards: anonymity undermines credibility | Govt: eyewitness account, contemporaneous details, excited statements, and use of 911 increase reliability | Court: Those features supported reliability; analogous to Navarette and Terry-Crespo — reasonable suspicion satisfied |
| Whether officers had to rely on dispatcher’s knowledge (and whether that knowledge could be imputed) | Edwards: dispatcher knowledge shouldn’t be imputed to officers (citing Colon) | Govt: dispatcher provided detailed, ongoing information; officers directly received sufficient information to form suspicion | Court: Distinguishable from Colon; officers had adequate direct information and did not need imputation |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1970) (Terry stop-and-frisk standard permitting limited search for officer safety)
- Florida v. J.L., 529 U.S. 266 (2000) (anonymous tip lacking predictive detail insufficient for stop)
- Alabama v. White, 496 U.S. 325 (1990) (anonymous tip with predictive detail can supply reasonable suspicion)
- Navarette v. California, 572 U.S. 393 (2014) (anonymous 911 tip of dangerous driving can create reasonable suspicion when tip shows eyewitness, contemporaneous knowledge, and danger)
- United States v. Terry-Crespo, 356 F.3d 1170 (9th Cir. 2004) (911 caller’s recorded, non-anonymous emergency call carries reliability supporting a Terry stop)
- United States v. Miles, 247 F.3d 1009 (9th Cir. 2001) (intrusive tactics like weapons drawn and handcuffing can be reasonable during a stop following a recent report of gunfire)
- Washington v. Lambert, 98 F.3d 1181 (9th Cir. 1996) (totality test for whether a stop becomes an arrest; considers intrusiveness and officer safety justification)