98 N.Y.2d 93 (2002)
An anonymous tip, even with a detailed description of a suspect, is insufficient to establish reasonable suspicion for a stop and frisk unless it includes predictive information that demonstrates the tipster’s knowledge or is corroborated by independent police observation of suspicious conduct.
Summary
The New York Court of Appeals addressed whether an anonymous tip, providing a description of an individual allegedly carrying a weapon, provides reasonable suspicion for a lawful stop and frisk. In People v. William II, police acted on an anonymous tip to stop and frisk a suspect and his companions. In People v. Rodriguez, police stopped a vehicle based on a tip describing a passenger. The Court held that without predictive information or independent corroboration of illegal activity, the anonymous tips did not justify the police intrusions. This decision reinforces the principle that reasonable suspicion requires more than just a description; it demands reliability in the assertion of illegality.
Facts
In William II, police received an anonymous tip that “Will” was involved in a recent drive-by shooting, providing a physical description and location. Officers found a person matching the description, Cruz, with two companions, including William II. Despite observing that Cruz was not dressed in a way that could conceal a weapon, police ordered him to be frisked. William II fled. The suppression court noted the officer had no reason to believe Cruz handed William II the weapon. William II was apprehended, and a search of his backpack revealed marihuana and drug paraphernalia.
In Rodriguez, police received an anonymous report of a light-skinned male Hispanic in a checkered shirt carrying a gun. Two hours later, they spotted Rodriguez, who matched the description, entering a car. They stopped the car, and Rodriguez dropped a gun from the window.
Procedural History
In William II, the County Court denied William II’s motion to suppress evidence, and the Appellate Division affirmed. The New York Court of Appeals reviewed the case.
In Rodriguez, the Supreme Court denied Rodriguez’s motion to suppress the gun. The Appellate Division reversed, and the People appealed to the Court of Appeals.
Issue(s)
1. Whether an anonymous tip providing a description of an individual allegedly carrying a weapon, without predictive information or independent corroboration of suspicious behavior, constitutes reasonable suspicion for a lawful stop and frisk.
2. Whether a traffic stop based solely on an anonymous tip describing a passenger in the vehicle is justified when there is no independent indication of criminal activity.
Holding
1. No, because the anonymous tip lacked predictive information or independent corroboration of illegal activity to provide reasonable suspicion for attempting to frisk William II.
2. No, because without more, the tip could not provide reasonable suspicion to stop the car.
Court’s Reasoning
The Court of Appeals relied heavily on Florida v. J.L., which held that an anonymous tip requires reliability in its assertion of illegality, not just in identifying a person. The Court emphasized that reasonable suspicion requires a “quantum of knowledge sufficient to induce an ordinarily prudent and cautious [person] under the circumstances to believe criminal activity is at hand”. In William II, the tip lacked predictive information, and police observed that Cruz could not have concealed a weapon. Moreover, there was no reason to believe the weapon was transferred to William II. The Court quoted Terry v. Ohio, stating that the inquiry is “whether the officer’s action was justified at its inception, and whether it was reasonably related in scope to the circumstances which justified the interference in the first place.” Since the initial stop was unjustified, the evidence obtained was inadmissible.
In Rodriguez, the Court found the stop unlawful based solely on the anonymous tip. The Court also determined that the gun could not be deemed abandoned because the stop itself was illegal, directly connecting to the unlawful stop. The court pointed to the arresting officer’s testimony who stated that he did not know it was a gypsy cab when he first stopped the vehicle.