State v. Simpson

An unnamed informant’s report may be sufficient to justify an officer’s reasonable suspicion to stop a vehicle if the informant’s report is sufficiently detailed, and the officer can corroborate at least some of the information contained in the report.

Defendant was convicted for DUII and failure to perform the duties of a driver when property was damaged. On appeal, he argued that the trial court erred in denying his motion to suppress evidence that the officer at the scene obtained after stopping his vehicle, because the unnamed informant’s 911 statement that defendant had committed the crimes in question were not sufficient to give the officer reasonable suspicion to make the stop. The Court of Appeals affirmed, finding that although the informant remained anonymous, her report was sufficiently detailed to infer that it was not fabricated, and in fact was based on personal observations. In addition, the officer was able to corroborate the report when he found that defendant’s car matched the model and license plate description from the report. Thus, the officer had reasonable suspicion to stop defendant’s vehicle. Affirmed.