State v. Harwood, 221 N.C. App. 451 (Jul. 3, 2012)

No reasonable and articulable suspicion supported seizure of the defendant made as a result of an anonymous tip. When evaluating an anonymous tip in this context, the court must determine whether the tip taken as a whole possessed sufficient indicia of reliability. If not, the court must assess whether the anonymous tip could be made sufficiently reliable by independent corroboration. The tip at issue reported that the defendant would be selling marijuana at a certain location on a certain day and would be driving a white vehicle. The court held that given the limited details contained in the tip and the failure of the officers to corroborate its allegations of illegal activity, the tip lacked sufficient indicia of reliability.

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