SAN DIEGO DISTRICT ATTORNEY The Fourth Amendment and ...

Corroboration:
Rule: Corroboration of an anonymous tip sufficient to justify a
detention and/or patdown for weapons can take various forms,
such as:
An accurate prediction of a suspect’s future activity (i.e.,
“predictive information;” see above) by the tipster.
Seemingly innocent activity when the anonymous tip casts
the activity in a suspicious light.
Presence of the person about whom the tip relates in a
“high crime area.”
Verification of details provided by the tipster through
police observation or other sources. (People v. Ramirez
(1996) 41 Cal.App.4 th 1608.)
Potential “accountability:”
Potential “accountability may help to corroborate an
informant’s information as well, such
“accountability” being in the form of:
The ability of authorities to identify the
informant;
The consequences the informant is likely to
experience as a result of providing false
information; and
The informant’s perception of these factors.
(People v. Jordan (2004) 121 Cal.App.4 th
544, 561-562.)
An in-person informant, even though unidentified,
supplies the necessary indicia of reliability for two
reasons:
An in-person informant risks losing
anonymity and being held accountable for a
false tip.
When a tip is made in-person, an officer can
observe the informant’s demeanor and
determine whether the informant seems
credible enough to justify immediate police
action without further questioning.
© 2012 Robert C. Phillips. All rights reserved
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