Florida v. J.L.

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Case Overview

CITATION

ARGUED ON

DECIDED ON

DECIDED BY

529 U.S. 266

Feb. 29, 2000

Mar. 28, 2000

Legal Issue

Does the search of an individual based solely on an anonymous tip received by the police violate their Fourth Amendment rights against unreasonable search and seizure?

Holding

Yes, the police may not stop and frisk an individual based solely on an anonymous tip that only describes their location and appearance without providing information regarding any illegal conduct that the individual might be planning.

Photograph of an officer from the Miami Dade Sheriff’s Office | Credit: Miami Dade Sheriff’s Office/Facebook

Background

On October 13, 1995, an anonymous caller reported to the Miami-Dade Police Department that a young black male was standing at a specific bus stop, wearing a plaid shirt, and carrying a gun. Two officers responded to the call and arrived to find three black males hanging out at the location. One of the individuals, J.L., who was ten days short of his sixteenth birthday, was wearing a plaid shirt. Apart from the anonymous report, the officers observed no firearm, witnessed no threatening or unusual movements, and had no independent reason to suspect any illegal conduct. One officer approached J.L., ordered him to place his hands against the bus stop, conducted a pat-down search, and seized a gun from his pocket. The second officer frisked the remaining two individuals and located no weapons.

J.L. was charged under Florida law with carrying a concealed firearm without a license and possessing a firearm while under eighteen years of age. J.L. filed a motion to suppress the weapon, arguing that it was the product of an unlawful search, and the trial court granted the motion. An intermediate appellate court reversed the trial court’s order, but the Supreme Court of Florida ultimately invalidated the search under the Fourth Amendment. The U.S. Supreme Court then granted certiorari.

Unanimous decision for J.L.

Florida

J.L.

Thomas

Scalia

Kennedy

Rehnquist

Stevens

Souter

O’Connor

Ginsburg

Breyer

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