SCOTUSblog: Navarette v. California
Argument: Jan 21 2014 (Aud.)
Background: Lorenzo and Jose Navarette were detained by officers of the California Highway Patrol (CHP) and subsequently arrested for transportation of marijuana and possession of marijuana for sale. The marijuana was discovered in the Navarettes' pickup truck during a traffic stop after the officers received a report from an unidentified citizen that the vehicle had been observed driving recklessly. The Navarettes' motion to suppress the evidence seized from their truck was denied, and they pled guilty to transportation of marijuana. On appeal, the Navarettes alleged that the evidence against them should have been suppressed because the anonymous tip received by police was insufficient to provide reasonable suspicion of criminal activity justifying an investigative stop of the vehicle, where the officers directly confirmed only significant innocent details of the tip but did not directly observe any illegal activity. The Court of Appeal of the State of California, First Appellate District, Division Five, affirmed the conviction. The Supreme Court of California denied review.
Issue: The question before the Court is whether the Fourth Amendment require an officer who receives an anonymous tip regarding a drunken or reckless driver to corroborate dangerous driving before stopping the vehicle.
Holding: In a 5-4 decision, the Supreme Court ruled 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.