Florida V. J. L.
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''Florida v. J. L.'', 529 U.S. 266 (2000), was a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...
case in which the Court determined that a police officer may not legally stop and frisk someone based solely on an anonymous tip that describes a person's location and appearance, but does not furnish information as to any illegal conduct.


Facts and procedural history

In 1995 the
Miami-Dade Police Department The Miami-Dade Sheriff’s Office (MDSO), formerly known as the Dade County Sheriff's Office (1836–1957), Dade County Public Safety Department (1957–1981), Metro-Dade Police Department (1981–1997), and Miami-Dade Police Department (1997â ...
received an anonymous tip that a young
black Black is a color that results from the absence or complete absorption of visible light. It is an achromatic color, without chroma, like white and grey. It is often used symbolically or figuratively to represent darkness.Eva Heller, ''P ...
male was at a
bus stop A bus stop is a place where Public transport bus service, buses stop for passengers to get on and off the bus. The construction of bus stops tends to reflect the level of usage, where stops at busy locations may have shelter (building), shelters ...
wearing a plaid
shirt A shirt is a cloth garment for the upper body (from the neck to the waist). Originally an undergarment worn exclusively by men, it has become, in American English, a catch-all term for a broad variety of upper-body garments and undergarments. ...
and carrying a
firearm A firearm is any type of gun that uses an explosive charge and is designed to be readily carried and operated by an individual. The term is legally defined further in different countries (see legal definitions). The first firearms originate ...
. The
police The police are Law enforcement organization, a constituted body of Law enforcement officer, people empowered by a State (polity), state with the aim of Law enforcement, enforcing the law and protecting the Public order policing, public order ...
went to the bus stop and saw three young black men, one wearing a plaid shirt. Acting solely on the tip (the officers did not observe any criminal or suspicious behavior), they searched all three, and found a pistol in the pocket of the man wearing the plaid shirt. At trial the court granted the juvenile defendant's motion to suppress
evidence Evidence for a proposition is what supports the proposition. It is usually understood as an indication that the proposition is truth, true. The exact definition and role of evidence vary across different fields. In epistemology, evidence is what J ...
as fruit of an unreasonable search and seizure. However, the
Florida Third District Court of Appeal The Florida Third District Court of Appeal is headquartered in Miami, Florida. Its ten judges have jurisdiction over cases arising from Miami-Dade County, Miami-Dade and Monroe County, Florida, Monroe Counties. History The Third District Court ...
reversed the trial court. J.L. appealed the decision to the
Florida Supreme Court The Supreme Court of Florida is the state supreme court, highest court in the U.S. state of Florida. It consists of seven justices—one of whom serves as Chief Justice. Six members are chosen from six districts around the state to foster geog ...
, which overruled the decision of the District Court of Appeal, holding that the tip did not give sufficient indicia of reliability to justify a stop and frisk of the subject. The appellee sought
certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of a prerogative writ in England, issued by a superior court to direct that the recor ...
review from the United States Supreme Court.


Opinion of the Court

The United States Supreme Court held in a unanimous opinion by
Justice In its broadest sense, justice is the idea that individuals should be treated fairly. According to the ''Stanford Encyclopedia of Philosophy'', the most plausible candidate for a core definition comes from the ''Institutes (Justinian), Inst ...
Ruth Bader Ginsburg Joan Ruth Bader Ginsburg ( ; Bader; March 15, 1933 – September 18, 2020) was an American lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1993 until Death and state funeral of Ruth Bader ...
that the search was unreasonable. That the tip accurately identified the defendant and that the allegation of the firearm ultimately proved to be accurate was insufficient to justify the seizure. For a completely anonymous tip to justify even a "stop and frisk" of a suspect pursuant to '' Terry v. Ohio'', 392 U.S. 1 (1968), it must be "suitably corroborated" with both the accurate prediction of future activity of the subject and accurate in its assertion of potential criminal activity. The tip given in the ''J.L.'' case was only sufficient to identify the subject and nothing more, making the police reliance upon it unjustified. The Court further declined to create a standard "firearms exception" to the ''Terry'' doctrine, as was recognized in some Federal circuits, stating, among other things, that " ch an exception would enable any person seeking to harass another to set in motion an intrusive, embarrassing police search of the targeted person simply by placing an anonymous call falsely reporting the target's unlawful carriage of a gun . . . ."''Florida v. J.L.'', 529 U.S. 266, 272 (2000).


See also

* List of United States Supreme Court cases, volume 529 *
List of United States Supreme Court cases This page serves as an index of lists of United States Supreme Court cases. The United States Supreme Court is the highest federal court of the United States. By chief justice Court historians and other legal scholars consider each chief j ...
*
Lists of United States Supreme Court cases by volume The following is a list of cases decided by the United States Supreme Court organized by volume of the ''United States Reports'' in which they appear. This is a list of volumes of ''U.S. Reports'', and the links point to the contents of each indiv ...


References


External links

* {{US4thAmendment, reasonable suspicion, state=expanded United States Fourth Amendment case law United States Supreme Court cases v. J.L. 2000 in United States case law Miami-Dade Police Department United States Supreme Court cases of the Rehnquist Court