CA7: ShotSpotter alert followed by 911 calls was RS when coupled with time of night and lack of other cars

Defendant’s car was driving out of the coverage area of a ShotSpotter alert. This was essentially an “anonymous tip” from ShotSpotter that was followed by 911 calls that independently confirmed it. The totality of the circumstances established that the officer stopped the car for more than just its location in ShotSpotter’s coverage zone. Altogether, the circumstances—the reliability of the police reports, the dangerousness of the crime, the stop’s temporal and physical proximity to the shots, the light traffic late at night, and the officer’s experience with gun violence in that area—provided reasonable suspicion to stop defendant’s vehicle. This is an issue of first impression. United States v. Rickmon, 2020 U.S. App. LEXIS 7614 (7th Cir. Mar. 11, 2020) (dissent).

Defendant didn’t properly frame his certified question for appeal to show that the search was illegal, and the Court of Criminal Appeals thus declines to address it. State v. Van Garrett, 2020 Tenn. Crim. App. LEXIS 179 (Mar. 11, 2020).*