TX: Anonymous tip was corroborated at the scene by officers for RS

An anonymous tip brought police to where defendant was, and their observations corroborated the tip sufficient to support reasonable suspicion. Furr v. State, 2016 Tex. Crim. App. LEXIS 1094 (Sept. 21, 2016) (dissent):

Here, as in J.L., the tip was sufficient only to identify the people that were allegedly engaging in illegal activity. J.L., 529 U.S. at 271-72. However, unlike in J.L., once police arrived on the scene, they made a number of independent observations supporting the tip that Collier and Furr had drugs and were using them. At the time Furr was detained, police had the following information: (1) an anonymous informant reported that two individuals on a specific street corner were using drugs; (2) Furr and Collier were at that the location and matched the descriptions provided by the tipster; (3) the police knew this location to be a “high drug, high crime” area; (4) Furr and Collier watched Alvarez as he drove past them; (5) when Alvarez approached Furr and Collier, Furr walked away furtively; and (6) when police found Furr in the shelter, he was sweaty, nervous, anxious, and seemed out of it, like he was under the influence of a drug. The observations of the police after arriving on the scene here distinguish this case from J.L., in which the only basis for the reasonable-suspicion determination was the anonymous tip giving the description of a person carrying a gun at a bus stop. J.L., 529 U.S. at 270. Based on the totality of the circumstances in this case, we hold that police had reasonable suspicion to detain Furr and investigate the allegations of drug use and possession based on the anonymous tip and the observations of responding police.