People v. Dacus.

2024 CO 51. No. 24SA2. Citizen Informant—Reasonable Suspicion—Investigatory Stop.

June 24, 2024

In this interlocutory appeal, the Supreme Court considered the district court’s order suppressing certain evidence obtained by a police deputy after the deputy was alerted to a possible drunk driver through a Report Every Drunk Driver Immediately (REDDI) report. In particular, the People contended that the district court erred in concluding that the REDDI report in this case constituted an anonymous tip requiring corroboration to justify an investigatory stop and that the People had presented insufficient corroborating evidence. In the People’s view, the tip at issue was not, in fact, anonymous, and even if it were, law enforcement had developed reasonable suspicion to conduct an investigatory stop. Alternatively, the People contended that the stop at issue was consensual.

The Court concluded that the tipster here was not anonymous, and therefore, the tip alone established reasonable suspicion to justify the stop. Even if the tip were anonymous, however, the Court further concluded that on the facts presented, reasonable suspicion supported an investigatory stop in this case.

Accordingly, the Court reversed the district court’s suppression order and remanded this case to the district court for further proceedings consistent with this opinion.

The full opinion is available at https://www.coloradojudicial.gov/system/files/opinions-2024-06/24SA2.pdf.