Appellant was convicted of battery on a police officer, after the trial court denied his suppression motion. The motion was based on appellant’s claim that the initial stop and detention were unlawful. The stop was made based on an anonymous tip that there was drug dealing from a car at a certain location. Officers arriving at the scene observed a hand-to-hand transaction, and detained appellant. The appellate court affirmed the denial of the suppression motion. The decision in Florida v. J.L. (2000) 529 U.S. 266 does not require reversal. The totality of the circumstances (the time the phone call was received, the exact description and match of the vehicle, the short period of time which passed between receipt and broadcast of the tip and the stop of the vehicle, etc.) was sufficient to support a temporary detention under J.L.
Case Summaries