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State v. Reno1/26/2004
defendant was committing a crime. See id. at 641-42.
We need not address the merits of the defendant's arguments regarding the sufficiency of the anonymous tip, because we disagree with the defendant's assertion that "[s]ince the information Cebollero had before stopping Reno's car was based solely on an anonymous tip from an informant, the law governing anonymous tips applies." As noted above, the trial court could reasonably have found that the information regarding the registered owner of the car and his suspension came not from the informant but from the dispatcher's check of the vehicle's plate number. We recognized in Richter the authority of police to run computer checks of passing vehicle licenses, without suspicion of criminal conduct. Id. at 640-41. Such checks are not searches under either the Fourth Amendment to the Federal Constitution or Part I, Article 19 of our State Constitution. Id. at 641. Thus, the officer lawfully obtained all the information needed to make a valid stop without relying on the informant. Because the Federal Constitution affords no greater protection to the defendant under these circumstances than does our State Constitution, see Richter, 145 N.H. at 641; Olabisiomotosho v. City of Houston, 185 F.3d 521, 529 (5th Cir. 1999) (no privacy interest in license plate number), we reach the same result under the Federal Constitution as under the State Constitution.
Affirmed.
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