NC: Recognizing tension between prior cases and Navarette, the court finds this stop the same as Navarette

The NC courts have long recognized detailed anonymous tips as providing reasonable suspicion for a traffic stop, even before Navarette. “However, in light of the State’s argument, we must acknowledge the apparent tension between our prior case law addressing similar factual scenarios and Navarette.” In this case, the court finds the anonymous tip almost factually the same, time line and all, with Navarette, and the stop is held valid. State v. Neal, 2019 N.C. App. LEXIS 766 (Sept. 17, 2019).

There was enough indicia of reliability that the anonymous tip standard did not apply. State v. Caddell, 2019 N.C. App. LEXIS 763 (Sept. 17, 2019).*