Florida v. J.L. Case Brief Summary | Law Case Explained
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Florida v. J.L. | 529 U.S. 266 (2000)
Under Terry versus Ohio, a police officer may conduct a warrantless investigatory detention of a person if the officer possesses reasonable suspicion that the person is engaging in criminal activity. The officer may frisk the person if the officer has reasonable suspicion that the person is armed. Imagine that an anonymous tipster called the police department and reported that you possessed an illegal concealed pistol and further provided them with your location in a public place. Based solely on that anonymous tip, could the police stop and frisk you consistent with the Fourth Amendment? The United States Supreme Court addressed this issue in Florida versus J.L.
An anonymous person called the Miami-Dade Police Department and reported that an unnamed young African-American male, who was standing at a particular bus stop in the city, was carrying a firearm. The caller said that the young man was wearing a plaid shirt. The caller then hung up. Six minutes later, police officers drove to the bus stop and saw three young African-American males. One of them had a plaid shirt. The officers didn’t see a firearm and also didn’t see any of the young men engaging in illegal or threatening behavior. One of the officers told the young man in the plaid shirt to put his hands on the bus stop. The young man complied. The officer patted him down and discovered a pistol in his pocket.
The officer arrested the young man, who was fifteen years old, and charged him with illegally possessing a concealed pistol by a person under eighteen. Florida’s juvenile court system prosecuted the young man. Because of his age, the court publicly identified him only by his initials, J.L.
J.L. moved to suppress the pistol under the Fourth Amendment. J.L. argued the officer didn’t have reasonable suspicion that J.L. illegally possessed a pistol when the stop and frisk occurred. The state trial court granted the motion. On the state’s appeal, the Florida District Court of Appeal reversed the trial court’s ruling, but the Florida Supreme Court reinstated the trial court’s order suppressing the pistol.
The state successfully petitioned the United States Supreme Court to review J.L.’s case.
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