Navarette v. California

Supreme Court of the United States · 2014 · Criminal Procedure

572 U.S. 393 (2014)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentInvestigative StopsAnonymous TipsReasonable SuspicionTerry stopanonymous tip911 call

Facts

A 911 caller reported that a silver Ford F-150 pickup with a specified license plate had run her off the road while traveling southbound on Highway 1 near mile marker 88. About 18 minutes later, a CHP officer located the truck near mile marker 69 and, after following it briefly and making a U-turn, stopped it without observing additional suspicious driving. As officers approached, they smelled marijuana, searched the truck bed, found 30 pounds of marijuana, and arrested petitioners. Petitioners argued that the stop was unconstitutional because the officer lacked reasonable suspicion.

Issue

Whether a traffic stop based on an anonymous 911 tip was consistent with the Fourth Amendment when the caller reported that a specific vehicle had run her off the road and the officer corroborated the vehicle's description, location, and direction of travel. More specifically, the question was whether the tip bore sufficient indicia of reliability and created reasonable suspicion of ongoing criminal activity such as drunk driving.

Rule

A brief investigative stop is permitted when an officer has a particularized and objective basis for suspecting the person stopped of criminal activity. When a stop is based on an anonymous tip, reasonable suspicion depends on the content of the information and its degree of reliability, assessed under the totality of the circumstances; a 911 tip may be sufficiently reliable when it reflects eyewitness knowledge, is made soon after the event, and is made through the 911 system, and a reliable report that a driver ran another vehicle off the road can create reasonable suspicion of ongoing drunk driving.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

At 10:15 p.m. in Tucson, a 911 caller reported that a black SUV with Arizona plate RKM-214 had just drifted into her lane on Interstate 10 and forced her onto the shoulder. Eight minutes later, an officer located the SUV traveling where the caller said it would be and stopped it without first observing any additional erratic driving.

Was the stop most likely supported by reasonable suspicion?

Explanation. A brief investigative stop is valid when the officer has a particularized and objective basis to suspect criminal activity. An anonymous 911 tip may supply reasonable suspicion when it bears adequate indicia of reliability, including apparent eyewitness knowledge, contemporaneous reporting, and corroboration of identifying details. A report that a specific vehicle forced another driver onto the shoulder closely resembles indicia of drunk driving, so the officer need not wait to observe more erratic driving before stopping the vehicle.