Florida v. J.L.
Citation and Court
529 U.S. 266 (2000), Supreme Court of the United States
Facts
An anonymous caller reported to police that a young Black male standing at a particular bus stop, wearing a plaid shirt, was carrying a gun. Officers went to the bus stop, found a person matching the description, and frisked him without observing any suspicious conduct. A firearm was found on him. No information about the tipster’s reliability or basis of knowledge was ever established.
Issue
Whether an anonymous tip that a person is carrying a gun, without more, justifies a Terry stop and frisk.
Holding
An anonymous tip alleging illegal gun possession, lacking indicia of reliability, does not justify a Terry stop and frisk; the tip here was insufficient to support reasonable suspicion.
Rule / Doctrine
An anonymous tip must exhibit sufficient indicia of reliability — including predictive information that police can corroborate — before it can furnish reasonable suspicion for a Terry stop. The Court also rejected a categorical “firearm exception” that would automatically justify a frisk whenever an anonymous tip reports gun possession.
Significance
Florida v. J.L. is the leading case limiting the use of anonymous tips to establish reasonable suspicion under Terry v. Ohio. It clarifies that the inherent anonymity of a tip, without corroboration of predictive detail or other indicia of reliability, cannot substitute for the particularized suspicion required by the Fourth Amendment. The Court explicitly declined to create a per se rule permitting frisks on anonymous gun tips.