Probable Cause for Further Investigation and Information Relayed to Patrol Officers

14-2-1579 State v. Rosario, App. Div. (per curiam) (10 pp.)

The appellate division court found that when a loss prevention officer relays information to police and identifies himself as such to the police on the call to police dispatch provided information based on his personal knowledge and observations that led him to report that defendant was about to engage in criminal activity, the dispatcher had specific and articulable facts supporting a reasonable suspicion to stop and detain defendant, which were imputable to the officer on the scene, and this information gave the officer a reasonable and articulable suspicion to conduct an investigative detention of defendant.   In other words, when the loss prevention officer at a bank, or retail store call the police and identifies a license plate and the observations of theft, even on a closed circuit camera, when that information is provided to a 911 police dispatcher, who then relays same to a patrol officer to conduct a motor vehicle stop, that is enough for probable cause for the police at that time to conduct a terry stop and investigate further.

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