Florida v. J.L.

SCOTUSCase
Litigants=Florida v. J.L.
ArgueDate=February 29
ArgueYear=2000
DecideDate=March 28
DecideYear=2000
FullName=Florida v. J.L.
USVol=529
USPage=266
Citation=120 S. Ct. 1375; 146 L. Ed. 2d 254; 2000 U.S. LEXIS 2345; 68 U.S.L.W. 4236; 2000 Cal. Daily Op. Service 2409; 2000 Daily Journal DAR 3226; 2000 Colo. J. C.A.R. 1642; 13 Fla. L. Weekly Fed. S 216
Prior=
Subsequent=
Holding=
SCOTUS=1994-2005
Majority=Ginsburg
JoinMajority="unanimous"
Concurrence=Kennedy
JoinConcurrence=Rehnquist
LawsApplied=Fourth Amendment (unreasonable searches and seizures), Terry v. Ohio.

"Florida v. J.L.", 529 U.S. 266 (2000), held that law enforcement cannot stop and frisk a citizen based solely on an anonymous tip describing only innocent behavior and which also does not sufficiently predict the future actions of its subject.

Facts and procedural history

In 1995 the Miami-Dade Police received an anonymous tip that a young black male was at a bus stop wearing a plaid shirt and carrying a firearm. The police went to the bus stop and saw three young black men, one was wearing a plaid shirt. Although, the officers did not observe any criminal or suspicious behavior, acting on the tip, one policeman frisked the wearer of the plaid shirt and found a pistol tucked in a pocket.

The trial court granted the juvenile defendant's motion to suppress evidence as fruit of an unreasonable search and seizure. However, the Florida Third District Court of Appeal reversed the trial court. J.L. appealed the decision to the Florida Supreme Court, which quashed the decision of the District Court, holding that the tip did not give sufficient indicia of reliability to justify a stop and frisk of the subject. The appellee sought certiorari review from the United States Supreme Court.

Holding and rationale

The United States Supreme Court held in a unanimous opinion by Justice Ruth Bader Ginsburg that the search was unreasonable. That the tip accurately identified the defendant and that the allegation of the firearm ultimately proved to be accurate was insufficient to justify the seizure. For a completely anonymous tip to justify even a "stop and frisk" of a suspect pursuant to Terry v. Ohio, 392 U.S. 1 (1968), it must be "suitably corroborated" with both the accurate prediction of future activity of the subject [see "Alabama v. White", 496 U.S. 325 (1990).] and accurate in its assertion of potential criminal activity. The tip given in the "J.L." case was only sufficient to identify the subject and nothing more, making the police reliance upon it unjustified.

The Court further declined to create a standard "firearms exception" to the "Terry" doctrine, as was recognized in some Federal circuits, stating, among other things, that "Such an exception would enable any person seeking to harass another to set in motion an intrusive, embarrassing police search of the targeted person simply by placing an anonymous call falsely reporting the target's unlawful carriage of a gun . . ." ["Florida v. J.L.", 529 U.S. 266, 272 (2000).]

ee also

* [http://supreme.justia.com/us/529/266/ Actual text of the U.S. Reporter]
* [http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=000&invol=98-1993 Full text of the opinion (findlaw)]

References