Law Enforcement Bulletin 

Question:  Can an anonymous tip that is corroborated by an officer’s training, experience, and on-scene observations support reasonable articulable suspicion of criminal activity?

Quick Answer:  Yes. A stop is lawful if the facts relayed in the tip are sufficiently corroborated by an officer’s training, experience, and observations that the suspect is engaged in criminal activity.
 
State v. Ross Third Appellate District, Marion County, March 30, 2015

Facts: At 3:30 a.m., Officer Gosnell responded to a fight with a gun call at 182 W. Columbia St.  He observed defendant Ross exit a vehicle that was parked in the parking lot adjacent to 182 W. Columbia St. and walk toward that house as if he were going to enter it. The car’s windows were frosted over as if he was parked there for a period of time.  There was not much foot traffic in the area. Officer Gosnell recognized the suspect as someone who he had previously dealt with regarding drugs and testified that, through his experience, guns and drugs go hand in hand. 

Importance:  An anonymous tip can form the basis for a Terry stop if the officer is able to articulate facts and circumstances that corroborate the tip. 
 
Keep in Mind: Remember, in this case the tip was backed up by the officer’s training, experience, prior experience with the defendant, and personal observations at the scene to form reasonable suspicion that the defendant was engaged in criminal activity. Officer Gosnell articulated during the suppression hearing the specific facts that led him to believe the suspect was involved in criminal activity and that he was armed. Under the totality of the circumstances analysis, the officer was able to justify his rationale for the stop.