6th: Silent 911 = anonymous tip

A 911 hang-up call did not provide police with enough reliable information to make a traffic stop near the home where the call originated, the 6th Circuit has ruled. (PDF)

We believe that the 911 hang-up call, standing alone without follow-up calls by a dispatcher
or other information, is most analogous to an anonymous tip. . . . The Supreme Court has made clear that an anonymous tip does not exhibit sufficient indicia of reliability merely because it provides “[a]n accurate description of a subject’s readily observable location and appearance,” J.L., 529 U.S. at 272, as such a tip “provide[s] no predictive information and therefore [leaves] the police withoutmeans to test the informant’s knowledge or credibility,” id. at 271.

A citizen may call 911 in order to report an emergency, be it criminal activity, a fire, or a medical emergency, but someone may also call 911 because he or she misdialed another number, accidentally activated a speed dial feature, or wished to pull a prank on the authorities. Thus, without any information from the caller, the silent 911 hang-up call was the
equivalent of an anonymous 911 report that there might be an emergency, which might or might not include criminal activity, at or near the address from which the call was made. In that sense, the silent 911 hang-up call could be said to have suggested the possibility of, among other things, a limited “assertion of illegality,” but, absent any observed suspicious activity or other corroboration that criminal activity was afoot, Officer Pender had no way of detehang-up call was reliable in even that limited possible assertion.