Benjamin has a Bachelors in philosophy and a Master's in humanities.
The Case Brief of Alabama v. White
If you are driving along and swerving from side-to-side, the police can pull you over as your actions provide a sign of probability or an indicia of reliability that you are driving while impaired. Police use all sorts of indicators and sources to investigate crimes, and one of the most controversial sources is the use of an anonymous tip to justify a stop and search.
Courts have raised concerns that an anonymous tip could lead to the rights of the defendant being trampled and have questioned the anonymous tip as to what information is needed to provide probable cause. After all, to establish probable cause for a stop or search when no crime is being committed openly, the police need to have more than hunches to back up their actions. In the case of Alabama v. White, the courts clarified the minimum requirements of an anonymous tip to provide probable cause for a police stop.
Vanessa White and the Anonymous Tip
In 1992, Vanessa White got into her brown Plymouth station wagon with a broken taillight and headed to Dobey's Motel. Vanessa did not know she was being tailed by undercover police officers who, on the basis of an anonymous tip by phone, pulled her over. They searched her car with her consent and found a briefcase with cocaine and marijuana in her car. She was arrested and charged with a crime. However, White challenged whether the anonymous tip that ended with her arrest truly constituted probable cause and plead guilty to the charges with the right to appeal in district court. White took her case to the Court of Criminal Appeals who found in her favor that the anonymous tip was not probable cause. In what became Alabama V. White, the Supreme Court took a hard look at the bare minimum requirements for probable cause when it comes to the use of anonymous tips.
The Supreme Court had heard cases on the use of anonymous tips before and had not found them unconstitutional, but mostly in the context of the totality of the circumstances. However, these cases had not specifically looked at what made an anonymous tip sufficient grounds for probable cause. The majority of the court, as argued by Justice Byron White, required that there is a sufficient indicia of reliability, or signs of probable cause. This meant that the source of the tip had more than the general public's information to warrant believability. In the case of Vanessa White, the tip stated where she was, where she would travel to, and what time she would leave. The description given to the police convinced the court that the source of the tip knew more than the general public due specifically to the fact that the tip predicted her actions of leaving her apartment and travelling to Dobey's Motel.
Not everyone on the Supreme Court was convinced. Justice Stevens was joined by Justices Brennan and Marshall in dissenting against the majority. Stevens questioned whether or not the indicia of reliability requiring the ability to predict future actions indicated a reasonable assumption of knowledge beyond that of the general public. As Stevens argues in his dissent, the movements of a person may only show that the person has a habit or schedule, not that the tip has inside knowledge beyond the public's. How would the police know that Vanessa did not have a regular shift at Dobey's Motel? Or that the caller was not just calling in as a prank or was not just observing the everyday actions with suspicion, but have no actual information of illicit activity?
The case of Alabama v. White revolves around what constitutes probable cause when it comes to anonymous tips. While the courts had ruled on the constitutionality of anonymous tips in establishing probable cause, the courts had not specifically addressed the minimum requirements of anonymous tips in establishing reasonable suspicion or an indicia of reliability. The court had previously relied on the totality of the circumstances standard for establishing probable cause, but here moved to clarify what that meant at a minimum. The Court found that, because the anonymous tip had information not available to the general public that was confirmed by observation, the tip was sufficient with all the other work done by police to constitute probable cause. Justice Stevens, with Brennan and Marshall, dissented from the majority and questioned whether the test of predicting future events really showed the tipster's inside knowledge of the accused.
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