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Name: People v. Coulombe
Case #: A091237
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 01/10/2001
Subsequent History: Review denied 4/11/01

The trial court erred here in ruling that the detention and pat-search of an individual, identified by two anonymous citizen informants as carrying a firearm, was illegal The Court of Appeal held that Florida v. J.L. (2000) 529 U.S. 266, which was relied on by the trial court, is distinguishable. J.L. involved only one anonymous telephone tip that a person matching defendant’s description and at a bus stop, had a gun. In Coulombe, the information that appellant had a gun was the subject of two separate tips. The tips were reported only a few seconds apart, and were reported in-person, thereby subjecting the tipsters to scrutiny and the risk of losing their anonymity. Moreover, the danger here was far greater because appellant was in a throng of thousands of people. In J.L., only two of the suspect’s friends were present at the bus stop. Because the trial court erred in granting the motion to suppress, the appellate court ordered the dismissed charges reinstated.