O'Toole v. Commonwealth

Only if an anonymous “tip” contains sufficient quality and quantity of detail to overcome the inherent unreliability that flows from the anonymity of its source does the “tip” rise to the level of reasonable, articulable suspicion, the standard required to conduct a Terry stop. Beckner v. Commonwealth, 15 Va.App. 533, 536-37, 425 S.E.2d 530, 532-33 (1993). When, as in this case, an informant relays to the police information from another unidentified person, the source of the “tip” is anonymous and has no inherent reliability. “‘It simply “makes no sense to require some indicia of reliability…