4th Amendment case by Hon. Amy Coney Barrett. Anonymous 911 call enough reasonable suspicion?

Hon. Amy Coney Barrett is the front-runner to be nominated to the Supreme Court. Let’s examine a criminal law and Fourth Amendment case authored by her in the 7th Circuit.

The case is United States v. Watson, 900 F.3d 892 (7th Cir. 2018). The police responded to a 911 call from a 14-year-old who borrowed a stranger’s phone and reported seeing “boys” “playing with guns” near a “gray and greenish Charger.” Officers blocked the vehicle and frisked the occupants, leading to the discovery of firearms. Watson was charged under 18 U.S.C. § 922(g)(1) and moved to suppress the evidence.

Watson argued the stop was unlawful because the anonymous tip did not provide reasonable suspicion. The government cited Navarette v. California, 572 U.S. 393 to argue the tip was reliable.

The Fourth Amendment requires reasonable suspicion to stop someone for potential criminal activity (Terry v. Ohio, 392 U.S. 1). Anonymous tips alone rarely suffice (Florida v. J.L., 529 U.S. 266), but certain factors, such as eyewitness knowledge, contemporaneous reporting, and use of 911, may increase reliability (Navarette, 134 S.Ct. 1683).

In Watson, the tip did not justify immediate seizure, highlighting nuances in Fourth Amendment law.

Full opinion here: https://casetext.com/case/united-states-v-watson-250

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