Partly Corroborated Tip, Prior History, Among Factors to Support Stop

US v. Howell: Police in Virginia got a tip from a previously reliable informant about a meeting between drug dealers that was to happen at a local hotel, which officers knew had a history of being used for drug dealing. When, after a few hours of surveillance, the target of the tip did not appear, they checked the guest register and found Howell was registered there. Officers knew that Howell had been previously part of drug trafficking investigations and had a prior drug conviction. They returned to surveillance and eventually a vehicle showed up that partially matched the tip, driven by Howell (who was not the target given by the tipster). After a brief trip inside the hotel and back out, Howell drove away and was shortly stopped. A drug dog alerted on and in the vehicle and officers recovered drugs. Howell was eventually convicted at trial of conspiracy to distribute drugs, distribution, and conspiracy to launder money, after the district court denied his motion to suppress the fruits of the stop and search of his vehicle.

On appeal, the Fourth Circuit affirmed Howell’s conviction and the denial of his motion to suppress. The court held that that totality of the circumstances present when the stop was made provided reasonable suspicion that criminal activity was afoot, even if some of the factors individually (Howell’s prior history, the hotel’s status, etc.) would not have created reasonable suspicion on their own. One of those factors was “Howell’s conduct in driving his vehicle” – that is, that he was “driving under the speed limit and giving unusually early turn signals.”