Prado Navarette v. California

PETITIONER: Lorenzo Prado Navarette and Jose Prado Navarette
RESPONDENT: California
LOCATION: Highway 1 near McKerricher State Park

DOCKET NO.: 12-9490
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT:

CITATION: 572 US (2014)
GRANTED: Oct 01, 2013
ARGUED: Jan 21, 2014
DECIDED: Apr 22, 2014

ADVOCATES:
Jeffrey M K Laurence - on behalf of the respondents
Paul R Kleven - on behalf of the petitioners
Rachel P. Kovner -

Facts of the case

On August 23, 2008, the Mendocino County dispatch center received a call from a Humboldt County dispatcher with the information that a silver Ford F150 pickup truck had run an unidentified vehicle off the road at mile marker 88 on southbound Highway 1. The original caller had also provided the license plate number of the pickup truck in question. The dispatch center broadcast that information to officers in the area, and two separate officers soon reported seeing the vehicle and began following it. The officers pulled the vehicle over, and while requesting information from the driver, smelled marijuana. During a search of the vehicle, the officers found four large bags of marijuana in the truck bed. The occupants of the vehicle, Lorenzo Prado Navarette and Jose Prado Navarette, were arrested for transportation of marijuana and possession of marijuana for sale.

At trial, the defendants moved to suppress the evidence obtained from the traffic stop and argued that the evidence did not establish a reasonable suspicion of wrongdoing to justify the stop. The state argued that the anonymous tip combined with the officers' observations of details that matched the tip constituted reasonable suspicion of the alleged reckless driving. The magistrate judge denied the motion. After the defendants petitioned for a review of this decision and were denied by both the California Court of Appeals for the First District, Division Five and the California Supreme Court, the defendants pled guilty. The California Court of Appeals for the First District, Division Five affirmed.

Question

Does the Fourth Amendment require an officer who received information regarding drunken or reckless driving to independently corroborate the behavior before stopping the vehicle?

Media for Prado Navarette v. California

Audio Transcription for Oral Argument - January 21, 2014 in Prado Navarette v. California

Audio Transcription for Opinion Announcement - April 22, 2014 in Prado Navarette v. California

Justice Thomas has our opinion this morning in case 12-9490 Navarette versus California.

This case comes to us on a writ of certiorari to the California Court of Appeals.

The Fourth Amendment permits brief investigative stops when an officer has a reasonable suspicion of criminal activity.

Reasonable suspicion requires a particularized and objective basis for suspecting a particular person of criminal conduct.

Our previous cases have recognized it under appropriate circumstances.

Anonymous tips can create reasonable suspicion.

In this case, an anonymous 911 caller reported that specific truck driving southbound on California Highway 1 had run the caller off the road.

A California Highway Patrol officer located the truck, stopped it, and discovered 30 pounds of marijuana.

Probably, it shouldn't carry around 30 pounds of marijuana, but petitioners argue that there was no reasonable suspicion for the traffic stop.

But the trial court denied petitioner's motion to suppress and California Court of Appeal affirmed.

In an opinion filed with the clerk today, we now affirm the judgment of California Court of Appeal.

We conclude that under the totality of circumstances in this case, the officer had reasonable suspicion that the driver of the truck was intoxicated.

First, there were adequate reasons for an officer to believe the caller's account of being run off the road.

The caller necessarily claimed the eyewitness knowledge of the incident.

The timeline of event suggested that the caller had little time to fabricate the report and the caller use the 911 system which had several technological and regulatory features that deter false reports.

The 911 call also created reasonable suspicion of drunk driving.

Running another car off the road suggest to sort of impairment that characterizes drunk driving.

That conduct bears too much resemblance to classic examples of drunk driving to be dismissed as isolated recklessness.

While there are other potential explanations for the reported behavior, we have consistently recognized that reasonable suspicion need not rule out innocent alternatives.

For these reasons, and others set forth in our opinion, we affirm the judgment of California Court of Appeal.

Justice Scalia has filed a dissenting opinion in which Justices Ginsburg, Sotomayor and Kagan have joined.

Sarah from Law Aspect

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