Summary
The District of Columbia Court of Appeals held that police lacked reasonable articulable suspicion to stop Everett Miles based on an anonymous 911 tip reporting a man shooting a gun and Miles's subsequent flight. The court concluded that the tip was insufficiently corroborated because the officers did not independently confirm the presence of a firearm before the stop. It reversed the denial of Miles's motion to suppress tangible evidence.
Holdings
- The police lacked reasonable articulable suspicion to stop Miles because the anonymous tip was not sufficiently corroborated in its assertion that he possessed or used a gun, and his flight under the circumstances was too equivocal to provide the necessary corroboration.
Questions Presented
- Whether the anonymous 911 tip was sufficiently corroborated to establish reasonable articulable suspicion that Miles was carrying a gun.
- Whether Miles's flight after an officer blocked his path and directed him to stop sufficiently corroborated the tip to justify a Terry stop.
- Whether the trial court erred in denying Miles's motion to suppress the tangible evidence recovered during the stop.
Disposition
reversed_and_remanded
Cases Cited (27)
- Terry v. Ohio, 392 U.S. 1 (1968)(followed)
- Sharp v. United States, 132 A.3d 161, 166 (D.C. 2016)(followed)
- United States v. Arvizu, 534 U.S. 266, 273-74 (2002)(followed)
- United States v. Cortez, 449 U.S. 411, 417-18 (1981)(followed)
- United States v. Sokolow, 490 U.S. 1, 7-8 (1989)(followed)
- Florida v. J.L., 529 U.S. 266, 268, 270-72 (2000)(followed)
- Plummer v. United States, 983 A.2d 323, 333 (D.C. 2009)(followed)
- Illinois v. Wardlow, 528 U.S. 119, 121-25 (2000)(distinguished)
- Navarette v. California, 134 S. Ct. 1683, 1687-90 (2014)(distinguished)
- Jackson v. United States, 109 A.3d 1105, 1106-09 (D.C. 2015)(distinguished)
Showing top 10 of 27.
Cited In (0)
No citing cases on record yet.
Court Document
Open PDFLoading document…