concurring in part and dissenting in part:
I concur in part III of the majority opinion concerning separation of powers. In part II of that opinion, however, the majority holds that the affidavit offered in support of an application for a warrant to search the residence of the defendant, Donald Hugh Pate, set forth sufficient facts to allow a judge to find probable cause for issuance of the warrant. The majority therefore concludes that the trial court properly denied the defendant’s motion to suppress evidence seized at his residence in execution of the warrant. I do not agree that the affidavit was sufficient to support a finding of probable cause, and therefore dissent to part II of the majority opinion.
I.
The affidavit for search warrant, signed on May 11, 1992, was based on a telephone tip from an anonymous caller (the caller), supplemented by police corroboration of some of the information in the tip and by some other facts obtained by police investigation. The caller stated that Michael Acosta had been *695arrested the previous week on New Mexico warrants for narcotics violations and that Acosta had a girlfriend named Lola Schafer. The caller then passed along information she had received from her girlfriend, “whose name she would not volunteer,”1 that Acosta had called Schafer to ask that Schafer arrange to have marijuana removed from his residence “because the Police were onto him.” The caller also related information obtained from the caller’s unidentified girlfriend that Schafer had used the unidentified girlfriend’s telephone, dialed 260-1716, spoke to someone she addressed as Donny, “and made arrangements for Donny to pick up the marijuana from Michael Acosta’s residence, and store it at Donny’s residence.” According to the unidentified girlfriend, the quantity of marijuana discussed in the conversation between Schafer and Donny was thirty-three pounds. The caller stated that she had never met Schafer or Donny and did not know where Donny lived.
The police then corroborated certain of the information. The officer who executed the affidavit called 260-1716 and talked to “a female who identified herself as MRS. PATE, at the address of 2853 Buttermilk Circle.” A check of the utilities listing for 2853 Buttermilk Circle produced the names of Donald H. Pate and Anita C. Pate. The affiant officer checked a criminal history on Donald Hugh Pate and found “a traffic record but no criminal arrests.” The officer also confirmed that a Michael Acosta had been arrested on May 9, 1992, on New Mexico warrants for possession of marijuana with intent to distribute and that he had been arrested in 1985 in Arizona for conspiracy to sell marijuana and in 1980 for felony larceny and first degree trespass. The officer also confirmed that Acosta was at the El Paso County Criminal Justice Center. The affidavit gave a description of the dwelling at 2853 Buttermilk Circle, stated that it was in Colorado Springs in El Paso County, and requested a search warrant for that dwelling. Based on the officer’s affidavit, a judge issued the search warrant that is contested in this proceeding.
II.
I agree with the majority’s summary of the abstract principles of law that apply when making a probable cause determination in cases such as this, where the affidavit in support of the search warrant is based on information provided by an anonymous informant. It is in the application of those principles to the facts of this case that I differ with the majority.
In determining the existence of probable cause, we have abandoned the two-pronged Aguilar-Spinelli test2 in favor of the totality of the circumstances test formulated by the United States Supreme Court in Illinois v. Gates, 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983). See People v. Paquin, 811 P.2d 394, 397-98 (Colo.1991); People v. Pannebaker, 714 P.2d 904, 907 (Colo.1986). Nevertheless, “[t]he totality-of-the-circumstances test does not lower the standard improbable cause determinations.... ” People v. Leftwich, 869 P.2d 1260, 1265 (Colo.1994), and the two prongs of Aguilar-Spinelli— veracity or reliability, and basis of knowledge — remain highly relevant considerations in assessing the totality of the circumstances. People v. Turcotte-Schaeffer, 843 P.2d 658, 661 (Colo.1993); see People v. Diaz, 793 P.2d 1181, 1183 (Colo.1990) (“informant’s reliability, veracity, and basis of knowledge are still important factors to be considered in determining whether probable cause exists”); People v. Contreras, 780 P.2d 552, 556 (Colo.1989) (basis of knowledge, veracity and reliability are important and are closely related considerations to be taken into account when determining if probable cause exists). Information within the affidavit for search warrant in the present case satisfied neither prong and failed to meet the ultimate test for the existence of probable cause: whether the affidavit supplied the judge with a substantial basis for concluding that a search would uncover evidence of wrongdoing. See Gates, *696462 U.S. at 236, 103 S.Ct. at 2331; Pannebaker, 714 P.2d at 907.3
Because the person who supplied the information to the police was anonymous and provided the information by telephone, it is impossible in this case to assess the veracity of the informant or the reliability of her information from the telephone tip itself. There is no indication that the informant had ever provided reliable information on past occasions, and her statements included no admission against penal interest. See Paquin, 811 P.2d at 394, 398 (emphasizing that the affidavit contained a statement that the confidential informant had purchased narcotics from the defendant and, further, that the informant had previously provided information that resulted in a felony arrest); Turcotte-Schaeffer, 843 P.2d at 661 (admissions against penal interest have traditionally been relied upon as a means of showing that information is reliable). The veracity deficiency is compounded because the caller did not purport to have personal knowledge of the facts concerning the call from Michael Acosta to Lola Schafer or from Schafer to “Donny,” but said that they were supplied to her by a girlfriend “whose name she would not volunteer.” Intrinsically, there is nothing in the informant’s call to the police to establish the veracity of the anonymous caller or the reliability of the information that she supplied.
Basis of knowledge was absent as well. The affidavit contains no information on the source of the caller’s information that Michael Acosta was arrested on New Mexico warrants for narcotics violations. The entire story concerning a telephone call from Acosta to Schafer and the later call by Schafer to “Donny”' asking Donny to pick up marijuana at Acosta’s residence and store it at Donny’s residence came from the anonymous girlfriend of the anonymous informant.4 The informant herself did not purport to have personal knowledge that this information was true.
I recognize, of course, that under the totality of the circumstances test, we do not accord independent status to veracity or reliability, and basis of knowledge:
Instead, they are better understood as relevant considerations in the totality-of-the-circumstances analysis that traditionally has guided probable-cause determinations: a deficiency in one may be compensated for, in determining the overall reliability of a tip, by a strong showing as to the other, or by some other indicia of reliability.
Paquin, 811 P.2d at 397 (quoting Gates, 462 U.S. at 233, 103 S.Ct. at 2329-30). In this case, however, there is nothing in the telephone tip itself to demonstrate the veracity of the informant, the reliability of the information, or an adequate basis for the informant’s purported knowledge. Therefore, absent some other sufficient indicia of reliability of the telephone tip, probable cause for the search is lacking.
The majority holds that police corroboration of several of the details provided by the informant is enough to compensate for the absence of demonstrated veracity or reliability and basis of knowledge and to satisfy the totality of the circumstances test. Where an informant’s allegations are insufficient by themselves to establish probable cause, it may be possible to overcome the deficiency by corroborating the details of the tip through independent police work. Gates, 462 U.S. at 241-45, 103 S.Ct. at 2333-36; Leftwich, 869 P.2d at 1267-68. These details need not necessarily relate to criminal activity. Gates, 462 U.S. at 243-44 n. 13, 103 S.Ct. at 2334-35; Leftwich, 869 P.2d at 1268.
The focus of a court in reviewing an affidavit that relies on corroboration of noncriminal activity is the degree of suspicion that attaches to particular types of corroborated non-criminal acts and whether the *697informant provides details which are not easily obtained. [Turcotte-Schaeffer; 843 at 660-61]. The purpose of the inquiry is to determine if the informer’s statements regarding non-incriminatory facts indicate familiarity with the implicated individual or the alleged criminal activity that would allow an inference that the informer’s allegations of criminal activity are reliable.
Leftwich, 869 P.2d at 1268. In this case, the police officer who executed the affidavit for arrest warrant verified only the criminal background and recent arrest of Acosta, and confirmed that a phone number provided by the informant led to a determination that Donald H. Pate lived at the address corresponding with that phone number. This corroboration was not sufficient to indicate that the informant or the anonymous girlfriend who supplied her with information was familiar with the defendant or the alleged criminal conduct so as to allow an inference that the informant’s allegations of criminal activity were reliable.
No degree of suspicion concerning the defendant could attach to the facts that were corroborated, nor does knowledge of those corroborated facts suggest a familiarity with the activities of Acosta or the defendant. Certainly, confirmation of a mere phone number cannot be said to suggest that the person who supplied the number was familiar with the activities of the persons to whom the number was listed. No other information confirmed by the officer had any connection with the defendant or his alleged criminal conduct. The allegation that the defendant had a relationship, direct or indirect, to Acosta or his girlfriend was never corroborated. Moreover, the facts that the officer verified, including the facts concerning Acosta’s arrest, were not difficult to obtain. “Facts that are easily obtained ... add little to the decision of whether probable cause for a search exists.” Leftwich, 869 P.2d at 1268.
The instant case is analogous to People v. Leftwich, which was decided by this court just a few months ago, in which we held that an affidavit in support of a warrant to search the defendant’s home did not establish probable cause. In that case, an anonymous letter was received by the Boulder Police Department. The letter gave information about a man whom the letter identified as “Jeff’ and described as “an active drug dealer.” Leftwich, 869 P.2d at 1264. It described the man and his car in some detail and informed police that the man collected drugs “at a music store located in Kansas City just North of the intersection of 39th and Main on the East side of the street. The collection times may coincide with the vacation times of the university in Colorado. The drugs are then taken to Boulder for resale.” Id.
Many of the non-incriminating factual details recited in the letter were independently corroborated by the police. They corroborated the description of the defendant, Jeffrey Leftwich, and the defendant’s automobile, including license plate number. They verified that the defendant was a student at the University of Colorado and had traveled in his van to Kansas City during spring break, and they also confirmed the existence of a music store located near 39th and Main in Kansas City — a “[k]nown ... high drug area.” Id. at 1264 n. 5.
Despite the corroboration, we determined that there was not a substantial basis for concluding that the defendant “was engaged in any illegal activity, let alone that drugs would be found in his house.” Id. at 1268. Even fewer relevant facts were corroborated in the present case. The majority distinguishes Leftwich on the basis that in the present case the information provided by the anonymous informant to the police established a nexus between the alleged illegal activity and the defendant’s home, a connection absent in Leftivich. Maj. op. at 692 n. 14. This overlooks the essential similarity that in Leftivich we also determined on a more detailed factual basis than present here that there was no probable cause to believe that the defendant was engaged in illegal activity.5
*698Consequently, I would hold that the affidavit, deriving its core of essential information from a story told by an anonymous caller and derived in important part from information provided by the caller’s unidentified girlfriend, did not provide the issuing judge .a substantial basis for concluding that there was probable cause to believe that drugs would be found at the defendant’s residence. The warrant was therefore invalid, and any ' evidence obtained pursuant thereto must be suppressed. I recognize the desirability and appropriateness of generally resolving doubts in favor of a magistrate’s determinations of probable cause in order to encourage applications for search warrant. See Gates, 462 U.S. at 236, 103 S.Ct. at 2331. However, this goal cannot vitiate the standard requiring that a magistrate have a substantial basis for concluding that probable cause exists before issuing a warrant. The majority’s holding that the affidavit in this case did provide the issuing judge with a substantial basis for concluding that probable cause existed to search the defendant’s residence sets an inappropriately low threshold for probable cause, thereby permitting governmental invasion of a home, an area at the core of Fourth Amendment privacy protections, on a lesser showing than constitutionally required. Therefore, I respectfully dissent to part II of the majority opinion.
Justice ERICKSON joins in this concurrence and dissent.
. The quoted material in this statement of facts appears in the affidavit for search warrant.
. Aguilar v. Texas, 378 U.S. 108, 84 S.Ct. 1509, 12 L.Ed.2d 723 (1964); Spinelli v. United States, 393 U.S. 410, 89 S.Ct. 584, 21 L.Ed.2d 637 (1969).
. The test is necessarily framed in somewhat general terms for, as the United States Supreme Court observed in Gates, "probable cause is a fluid concept — turning on the assessment of probabilities in particular factual contexts — not readily, or even usefully, reduced to a neat set of legal rules.” Gates, 462 U.S. at 232, 103 S.Ct. at 2329.
. "[T]he giving of a detailed story by itself does not establish reliability because an informant could simply tell an elaborate lie.” Turcotte-Schaeffer, 843 P.2d at 662. Some other indicia of reliability are necessary.
. It is also instructive to recall the facts of Illinois v. Gates in which the United States Supreme Court first enunciated the totality of the circumstances test for probable cause. In brief, the police in Illinois received information through an anonymous letter advising that a named husband and wife who lived at a particular location in Illinois were selling drugs for a living and de*698scribing in some detail their modus operandi in obtaining those drugs in Florida and returning them to Illinois. The letter referred to a particular trip planned by the couple to obtain more drugs, including the date the wife would depart for Florida by car and the information that the husband would follow in a few days to return with the car and the drugs while the wife would return by plane. The police through investigation and surveillance verified that the couple traveled to Florida as predicted, one by car and the other by plane, and conducted themselves in the manner described as their modus operandi by the anonymous letter writer. On the basis of this information, the police in Illinois obtained a warrant to search the automobile upon its return to Illinois and the residence of the couple, and the search was ultimately sustained as constitutional by the United States Supreme Court. Illinois v. Gates, 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983). The contrast between the degree of detail in the tip and the extent of corroboration by the police in Gates and that existing in the present case makes apparent that the majority is applying the totality of the circumstances doctrine to find probable case based on a much more attenuated showing of reliability than existed in the case that gave the doctrine birth.