Florida v. J. L.

Facts of the case

On October 13, 1995 Miami-Dade police received an anonymous tip that a black mal
e wearing a plaid shirt was standing near a bus stop carrying a gun. The two off
icers who responded found three black males, one of which, J.L., a 15 -year-old,
was wearing a plaid shirt. After frisking him, the officers did find a firearm.
J.L. was charged with carrying a concealed weapon without a license. At trial,
he moved to suppress the gun as evidence, arguing that the frisking performed by
the officers was illegal under the Fourth Amendment. The trial court granted th
e motion, but was reversed by the immediate appellate court. The Florida Supreme
Court overruled the appellate court and suppressed the evidence.

Question

Did searching J.L. solely on the basis of the anonymous tip received by the Miam
i-Dade police violate his Fourth Amendment rights against unreasonable search an
d seizure?

Conclusion
Yes. In a unanimous opinion authored by Justice Ruth Bader Ginsburg, the Court c
oncluded that J.L. the anonymous tip did not meet the minimum requirements to pe
rform a warrantless search. Justice Ginsburg, drawing from the Court's logic in
Terry v. Ohio and Adams v. Williams, indicated that an anonymous tip must posses
a moderate level of reliability, including "predictive information" that offers
police a "means to test the informant's knowledge or credibility." An accurate
description of a person without a reliable assertion of illegality or descriptio
n of the crime in question, as was the anonymous tip in this case, does not meet
this standard. "All the police had to go on in this case was the bare report of
an unknown, unaccountable informant who neither explained how he knew about the
gun nor supplied any basis for believe he had inside information."