Following is the case brief for Alabama v. White, Supreme Court of the United States, (1990)
Case summary for Alabama v. White:
- Based on an informant tip, officers camped outside of Vanessa Rose White’s home as part of their investigation.
- Shortly after White left her address driving her car, both of which were described in the tip, officer’s stopped White’s car. White consented to a search and the police found marijuana in the briefcase described to have cocaine inside.
- The court of appeals held that the stop was unconstitutional because it violated White’s Fourth Amendment rights.
- The Court held that the stop was lawful because it was based on reasonable suspicion which was established after the tip corroborated with the following events leading up to the officers pulling over White.
Alabama v. White Case Brief
Statement of the facts:
Officers were provided with an anonymous tip stating that White would be carrying a briefcase outside of her home which contained cocaine. The tip also provided officers with a description of White’s car, address and the hotel to which she would be arriving with the briefcase. Based on this information, police surveillance was set up outside of Whit’s home. After arriving at the provided address, officers observed White walking out to the car described in the informant’s tip without the briefcase. Officers stopped White prior to her arriving at the hotel and explained they were looking for a briefcase. White consented to a search of her car and a briefcase was subsequently recovered, to which she provided the combination to. The briefcase contained marijuana and White was arrested. Three milligrams of cocaine was discovered in White’s purse shortly after.
White appealed her convictions, and the court of appeals held the stop lacked reasonable suspicion. The Supreme Court of the United States granted certiorari to hear the case.
Rule of Law or Legal Principle Applied:
When deciding whether or not an informant’s tip offers reasonable suspicion, the totality of the circumstances needs to be considered, in addition to the reliability and basis of the informant’s knowledge.
Issue and Holding:
Whether an anonymous tip partially corroborated by officer surveillance is sufficient reasonable suspicion? Yes.
The Court reversed the court of appeal’s judgment.
The Court pointed out to precedent in Illinois v. Gates, 462 U.S. 213 (1983), which states when determining whether an informant’s tip are sufficient to establish probable cause, the totality of the circumstances must be taken into consideration. This test also applies in determining whether an informant’s tip constitutes reasonable suspicion when an officer is considering stop a car.
The standard for establishing reasonable suspicion is lower than probable cause. Establishing reasonable suspicion only requires police to be able to articulate the specific facts in support of their alleged suspicion.
It is ok for the amount and caliber of the informant’s information to be less than what is necessary for probable cause. In addition, the information provided can also be less reliable than the higher probable cause standard.
In this case, the totality of the circumstances amounts to reasonable suspicion since a portion of the informant’s tip were corroborated by the officer’s surveillance investigation. Officer’s watched White left the address the informant had provided in a car which matched the description. As a result, it was reasonable for officers to assume she was on her way to the hotel since the officers stopped White just before she arrived there.
Since the informant was right about the above details, specifically White’s future behavior, The Court held it was reasonable for the officers to assume the informant was correct about other details concerning drug possession, because the informant was correct about the details provided in the tip. As a result, the informant’s tip was properly corroborated to support the officer’s reasonable suspicion.
Concurring or Dissenting opinion:
The officers failed to establish reasonable suspicion to make the stop. This is because the informant provided no more substantive information than a disgruntled neighbor may have.
Alabama v. White set the standard for establishing reasonable suspicion based off of an anonymous tip. The reliability of the tip must be taken into consideration when assessing its basis for establishing reasonable suspicion. It is important not to hold this level of reliability to that of establishing probable cause.