Florida v. J.L Case Brief

Florida v. J.L., 529 U.S. 266, 120 S.Ct. 1375 (2000)

FACTS: Miami-Dade officers received an anonymous tip that a young black male was standing at a particular bus stop, wearing a plaid shirt, and that he was in possession of a gun. A few minutes later, officers found J.L., along with two other young men, wearing a plaid shirt, at that location. The officers observed no suspicious conduct, nor did they see anything to lead them to suspect that J.L. had a weapon. They seized and frisked J.L., and found a firearm.

ISSUE: Can an anonymous tip alone, with no other corroborating information, give reasonable suspicion to frisk for a gun?

HOLDING: No

DISCUSSION: The Court held that an anonymous tip that is unsupported by specific information about a firearm is not sufficient to satisfy the requirement of Terry that an officer have reasonable suspicion before initiating a search. In this case, the officers had nothing but an anonymous tip about an individual carrying a firearm. An exception strictly because a firearm is alleged would subject individuals to the potential for harassment by officers acting solely on anonymous tips that may, or may not, be credible. The Court insists on at least an indicia of reliability and credibility in anonymous tips.

The Court specifically stated that this case does not reach to areas where an individual has a diminished expectation of privacy, such as airports and schools.