Saturday, November 2, 2013

Alabama v. White case brief

Alabama v. White case brief summary
496 U.S. 325 (1990)

CASE SYNOPSIS
Certiorari was granted to review an order of the Court of Criminal Appeals of Alabama, which held that officers did not have the reasonable suspicion necessary to justify an investigatory stop of respondent's car and that the marijuana and cocaine that the officers seized were fruits of respondent's unconstitutional detention.

CASE FACTS
The State sought review of a judgment holding that officers did not have the reasonable suspicion necessary to justify an investigatory stop of respondent's car based on an anonymous tip and that marijuana and cocaine seized were fruits of respondent's unconstitutional detention.

DISCUSSION
  • On appeal, the United States Supreme Court reversed and remanded, noting that a "totality of circumstances" approach was used to determine whether an informant's tip established probable cause or the reasonable suspicion required by an officer to make a Terry stop. 
  • The level of suspicion required for a Terry stop was less demanding than that required for probable cause, and reasonable suspicion could arise from information less reliable than that required to show probable cause. 
  • When the officers stopped respondent, the anonymous tip had been sufficiently corroborated to furnish reasonable suspicion that respondent was engaged in criminal activity. 
  • The investigative stop, therefore, did not violate U.S. Constitutional Amendment IV. 
  • When significant aspects of the informant's predictions were verified, there was reason to believe that the informant was honest and well-informed.

CONCLUSION

The Court reversed the judgment of the appellate court and remanded for further proceedings because when the officers stopped respondent, the anonymous tip from the informant had been sufficiently corroborated to furnish reasonable suspicion that respondent was engaged in criminal activity. The investigative stop did not violate the Fourth Amendment.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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