Law School Case Brief
Navarrete v. California - 572 U.S. 393, 134 S. Ct. 1683 (2014)
The Fourth Amendment permits brief investigative stops when a law enforcement officer has a particularized and objective basis for suspecting the particular person stopped of criminal activity. The reasonable suspicion necessary to justify such a stop is dependent upon both the content of information possessed by police and its degree of reliability. The standard takes into account the totality of the circumstances—the whole picture. Although a mere hunch does not create reasonable suspicion, the level of suspicion the standard requires is considerably less than proof of wrongdoing by a preponderance of the evidence, and obviously less than is necessary for probable cause.
California Highway Patrol officers received a 911 report that a pickup truck of a certain description had run another motorist off the road. One officer spotted a truck that matched the description given, and he stopped it; another responding officer stopped to assist. As the officers approached the truck, they smelled marijuana. A search of the truck bed revealed 30 pounds of marijuana. The officers arrested the driver, petitioner Lorenzo Prado Navarette, and the passenger, petitioner José Prado Navarette. At trial in California state court, petitioners filed a motion to suppress the marijuana, arguing that the officer who stopped their truck lacked reasonable suspicion to conduct a stop. The trial court denied the motion and the Court of Appeal of California, First Appellate District, affirmed. Petitioners were granted a writ of certiorari.
Did the traffic stop comply with Fourth Amendment?
The Supreme Court of the United States affirmed the state appellate court's judgment. The Court held that the traffic stop complied with the Fourth Amendment because, under the totality of the circumstances, the officer had reasonable suspicion that the truck’s driver was intoxicated. The Fourth Amendment permitted brief investigative stops—such as the traffic stop of petitioners' truck—when a law enforcement officer had a particularized and objective basis for suspecting the particular person stopped of criminal activity. These principles applied with full force to investigative stops based on information from anonymous tips. The 911 call bore adequate indicia of reliability for the officer to credit the caller's account. The officer was therefore justified in proceeding from the premise that the truck had, in fact, caused the caller's car to be dangerously diverted from the highway.
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