CA11: Anonymous 911 call with eyewitness details was RS

“Bruce insists that the officers had no reason at all to find the anonymous tip reliable, but that’s just not so. For purposes of a brief investigatory detention like the one we consider here, an anonymous 911 call giving eyewitness details of a real-time event is reliable enough ‘to credit the caller’s account.’ Navarette, 572 U.S. at 398 …” United States v. Bruce, 2020 U.S. App. LEXIS 31959 (11th Cir. Oct. 8, 2020).

“While the case is close, the officers can point to specific and articulable facts that give rise to reasonable suspicion. Alvarez matched the description of the subject who had an outstanding warrant. He was a Hispanic male, he rode a bicycle with particularly large handlebars, and he was spotted in the area where the subject was known to reside. While each of these factors individually may be insufficient to justify an investigatory stop, collectively, they are not so general as to negate reasonable suspicion.” United States v. Alvarez, 2020 U.S. Dist. LEXIS 186852 (S.D. Tex. Oct. 8, 2020).*

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