N.D.Ill.: Detailed 911 call was RS

This detailed 911 call provided reasonable suspicion. “The answer is somewhere in the middle, but ultimately favors the government’s view. It is a close call, but the anonymous tip in this case contained just enough indicia of reliability to support a finding of reasonable suspicion. For one, the 911 call here is far more detailed than the ‘bare-bones tip’ in J.L. Navarette, 572 U.S. at 398. In J.L., the caller merely said that a person of the defendant’s description possessed a gun at a specific location, but did not otherwise explain how the caller knew about the gun or provide any indication that he had ‘special familiarity’ with the case. Id. Nor did the tip include any ‘predictions of future behavior that could be corroborated to assess the tipster’s credibility.’ Id. So, if the anonymous caller in this case had simply reported that there was a man in a black coat and hat with a gun at the corner of 79th and Halsted and hung up, then that by itself might not have been enough to justify reasonable suspicion under J.L. But that is not what happened here. [¶] Here the caller also provided additional details lending credibility to the tip. This call was much more than just a bare-bones description of appearance and location. Rather, the caller described Swinney’s entire outfit, down to the fur trim on his coat, and also provided a play-by-play narrative account of his actions and movements, not just a static location, over the course of one-and-a-half minutes. United States v. Swinney, 2020 U.S. Dist. LEXIS 95614 (N.D. Ill. May 30, 2020).

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