CA7: Anonymous call of suspicious person lacked corroboration and wasn’t RS

This anonymous tip revealed nothing but identifying characteristics, and it didn’t show reasonable suspicion. “Additionally, the tip itself contained no further indicia of the informant’s reliability. It also offered nothing but a barebones description of the suspect: the caller identified the race (Hispanic), sex (male), and dress (black sweater, hat, and bag). What limited details the caller did supply fell short of describing Howell with significant accuracy. Above all else, the call mentioned a bag, which Howell did not have, and described Howell, who is white, as appearing Hispanic.” United States v. Howell, 2020 U.S. App. LEXIS 14142 (7th Cir. May 4, 2020).

An apartment maintenance man was sent in by his supervisor, and the testimony “demonstrates that Mr. Bowie’s superiors wanted him to look for ‘illegal things,’ like drugs, ‘that are not allowed on our property.’ … A search by a private individual to further the interests of a property manager does not implicate Fourth Amendment concerns.” United States v. McArthur, 2020 U.S. Dist. LEXIS 77628 (M.D. Ala. May 4, 2020).

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