The Supreme Court heard arguments over whether officers had reasonable, articulable suspicion to seize and pat down Jeffrey Antonio Barlow after an anonymous tip and a brief officers' encounter, with Abigail L. Paulus, the appellant's counsel, asking the court to reverse the Court of Appeals.

Paulus told the court that on Oct. 3, 2019, Richmond Police “seized Jeffrey Barlow without reasonable suspicion that he was engaged in criminal activity. They subjected him to a pat down without reasonable suspicion that he was armed and presently dangerous,” and later to a strip search without meeting the appellate standard. She argued the anonymous CAD report supplied at 04:43:53 was vague—initially saying “a man in a white Nissan has drugs,” later adding “possible weapons” and an update that a man with a white shirt on his head might have a gun—and did not predict future behavior or identify the tipster as an eyewitness.

“There's nothing in the tip that predicts future behavior,” Paulus said, adding officers arrived about 20 minutes after the call and encountered two men, not four as the tip described. She cited body-camera timing to contend Barlow was seized before officers recovered a firearm on another individual: “Officer Manns grabs the cell phone from Barlow at 46 seconds into his body cam… Gun discovered was 53 seconds into the video,” Paulus said, arguing those moments show Barlow had been touched and patted down prior to any gun recovery and therefore the seizure and pat down lacked individualized reasonable suspicion.

Aaron Campbell, senior assistant attorney general arguing for the Commonwealth, urged the court to view the encounter under the totality of the circumstances, likening the case to earlier authority the Commonwealth said supported a protective seizure. “The officers in this case faced two situations where they had to act quickly for the safety of themselves, the defendant, and the others on the scene,” Campbell said, arguing that the anonymous tip, the presence of a white vehicle, matching clothing descriptors, and an observed furtive movement by the other person supported a reasonable suspicion sufficient to detain and pat down Barlow.

Campbell walked the court through the body-camera sequence described in the transcript, saying an officer observed what he thought was an outline or bulge at the waistband of the other person, Taylor, who then reached toward his waistband and was seized; Campbell said the handgun was recovered around the 53-second mark and that officer Manns seized Barlow’s phone “one second after” the seizure of Taylor, an order of events he argued justified the officers’ actions.

Justices questioned counsel on the proper legal benchmarks. The panel discussed whether decisions such as Terry, Florida v. J.L. (JL), and the court’s prior cases permit officers to rely on corroboration of descriptive details from anonymous tips, and whether the officers may aggregate knowledge of co-officers on the scene. Paulus emphasized the requirement for particularized suspicion as to Barlow himself and warned against a per se companion rule that would impute another suspect’s conduct to Barlow without individualized facts.

The arguments focused on whether the anonymous tip and the limited corroboration by officers (vehicle location, clothing descriptors) were sufficient under existing precedent to justify seizing and patting down a person who, according to Paulus, “has done nothing” before being grabbed. Campbell maintained that the totality of circumstances—tip plus on-scene observations including another suspect’s furtive motion—made the officers’ response reasonable.

The advocates did not announce a decision from the bench. After argument, counsel asked the court to reverse (Paulus) or to affirm (Campbell) the Court of Appeals’ judgment.