Prado Navarette v. California

Background

A 911 caller reported that a silver Ford F-150 ran her off the road and gave the truck’s license number and location. A California Highway Patrol officer later found that truck, stopped it, smelled marijuana, searched the bed, found about 30 pounds of marijuana, and arrested the driver (Lorenzo Prado Navarette) and passenger (José Prado Navarette). The drivers sought to suppress the evidence, lower courts denied relief, and the case reached this Court.

Reasoning

The central question was whether the officer lawfully stopped the truck based on the anonymous 911 report. The Court said yes: under the Fourth Amendment an officer may make a brief stop when there is reasonable suspicion of criminal activity. The Court relied on the totality of the circumstances — the caller’s claim of eyewitness knowledge, the timely report, the officer’s corroboration of the truck’s description and location, and the use of 911 — and concluded those facts gave reasonable suspicion that the driver might be intoxicated.

Real world impact

The ruling allows officers to rely on similar 911 reports, combined with on-scene corroboration, to make investigative traffic stops on suspicion of dangerous or drunk driving. The decision affirmed the drug evidence seized after this stop. The Court called this a close case, so the holding rests on the specific mix of facts here and may not resolve all future situations.

Dissents or concurrances

Justice Scalia (joined by three Justices) dissented, arguing the anonymous tip was unreliable, the report did not allege drunkenness, and five minutes of harmless driving undermined any suspicion; he would have reversed the stop.