Silent 911 call does not create Reasonable Suspicion

The Sixth Circuit affirmed a trial court's motion to suppress evidence in United States v. Cohen. In that case, police officers responded to a silent 911 call. Although other circuits have ruled that a 911 call is more reliable than an anonymous tip, the court declined to extend that rule to the facts of this case "Given the almost complete absence of information communicated by the silent 911 hang-up call and the limited additional information known to Officer Pender when he stopped Cohen’s car." The court held that, under the totality of the circumstances, the police officers did not have reasonable suspicion to conduct the investigatory stop.

Courts Citing to Wikipedia

As I was reading COA's decision in Frost v Minnesota Life Insurance Co, I noted the court's citation to DSM-IV (the leading diagnostic treatise for mental disorders). That citation made me recall another case where the Michigan Supreme Court cited to Wikipedia to define a psychological term. In MDOT v Haggerty Corridor, Justice Young relied on Wikipedia to define a psychological phenomenon known as "hindsight bias" (see note 36 of the opinion). In Justice Young's defense, the case had nothing to do psychology; instead he was making an analogy. But it seems that the courts are more willing to cite to Wikipedia, and presumably so are the litigants before them. It seems dangerous to rely on a "source" that can be edited by anyone at any time, regardless of accuracy of the post or expertise of the poster.