Alabama v. White
Citation and Court
496 U.S. 325 (1990) — Supreme Court of the United States
Facts
An anonymous caller told police that White would be leaving a specific apartment building at a specified time, would be carrying cocaine in a brown attache case, and would drive a brown Plymouth station wagon to a specific motel. Officers observed White leave the building, enter a station wagon, and drive toward the motel before stopping her. A search of the car revealed marijuana and cocaine.
Issue
Can an anonymous tip, sufficiently corroborated by police observation of the predicted behavior, provide the reasonable suspicion necessary to justify an investigatory stop?
Holding
Yes; an anonymous tip that is sufficiently corroborated by independent police investigation can establish the reasonable suspicion necessary for a Terry stop, even if it would not support a finding of probable cause.
Rule / Doctrine
Reasonable suspicion can be established by an anonymous tip when the tip contains predictive information that police corroborate before acting, because accurate prediction of innocent-seeming future behavior suggests the tipster has inside knowledge and is therefore more reliable. The totality of the circumstances governs the analysis.
Significance
Alabama v. White is a key case on the use of anonymous tips to establish reasonable suspicion. It sits between the corroboration-heavy standard of Illinois v. Gates (probable cause) and the more demanding standard of Florida v. J.L. (which later held that bare anonymous tips of concealed weapons are insufficient), and it establishes that corroboration of predictive details can elevate an otherwise bare tip to the level of reasonable suspicion.