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.