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CA6: 911 hang up call ("silent 911 call") not RS in itself; it is like an anonymous tip requiring more

By John Wesley Hall, Jr.

A 911 hang up call is analogous to an anonymous tip, and it alone cannot form the basis of reasonable suspicion. It may, however, be a factor in reasonable suspicion. Defendant’s flight may not be reasonable suspicion alone, but it can be in conjunction with other things. Here, it all added up to reasonable suspicion for a stop. United States v. Smith, 2010 U.S. App. LEXIS 2739, 2010 FED App. 0032P (6th Cir. February 10, 2010): Smith contends that the 911 call is not a significant factor in considering the totality of the circumstances. Smith argues and the district court appears to have assumed that the emergency 911 call was a silent or hang-up 911 call. In examining the 911 call, this court has found that a 911 hang-up call "standing alone without follow-up calls by a dispatcher or other information, is most analogous to an anonymous tip...continue to full post

Full post as published by Fourth Amendment on February 14, 2010 (boomark / email).