dissenting:'
In this case the trial court, concluding that an affidavit submitted in support of a search warrant was “substantially misleading” and that the police officer submitting the warrant intentionally omitted relevant information concerning the credibility of a victim informant, entered an order prohibiting the introduction of certain evidence seized pursuant to the warrant. The majority reverses that order on the basis of its view that statements of a victim generally need not be corroborated before they are repeated in an affidavit, maj. op. at 1343; its conclusions that the omitted evidence “would not have significantly affected” the issuing court’s probable cause determination, maj. op. at 1346, and did not constitute “‘contrary evidence’ that would require a showing of the victim-informant’s credibility or corroboration of the victim’s account,” maj. op. at 1346; and its determination that the trial court’s finding that the officer intentionally omitted relevant information from the affidavit is “not supported by the record.” Maj. op. at 1348.1 Because I find the record fully supportive of the trial court’s critical factual determinations and believe the majority opinion does not appropriately apply well-established rules of law respecting the adequacy of affidavits submitted in support of requests for search warrants, I respectfully dissent.
A
The majority has appropriately indicated that the issue in this case requires consideration of information known to a police officer, Detective Hunt, and omitted by Hunt from an affidavit he prepared in support of an application for the issuance of a search warrant. In gathering information concerning a sexual assault allegedly committed by the defendant, Timothy Fortune, on the then eleven-year-old C.S., Hunt and Officer David Hagan interviewed C.S. and C.S.’s father on *1349two occasions. With respect to the information supplied by C.S.’s father, the affidavit in four sentences summarizes statements made by the father describing comments made to him by C.S. As the majority notes, the affidavit does not refer to statements by the father that C.S. was suffering from a “detachment and abandonment disorder”; that in the father’s opinion C.S. was capable of fabrication, was a “con-artist” and a “good actor”; and that C.S. could make up stories at times. Maj. op. at 1344. In addition, the record reveals that the father informed the officers that C.S. had severe behavioral problems requiring extensive therapy and that C.S. had at one time been treated for over 400 days at an inpatient hospital for such behavioral problems. Furthermore, the trial court found that C.S. “had made false allegations of physical abuse before,” and the People have not disputed that factual finding.2
B
In People v. Sundermeyer, 769 P.2d 499, 501 (Colo.1989), we observed that the test for determining whether the omission of information known to the affiant at the time an affidavit for a search warrant is executed is “whether the omitted facts rendered the affidavit substantially misleading to the judge who issued the warrant.” See also People v. Unruh, 713 P.2d 370, 381 (Colo.1986); People v. Winden, 689 P.2d 578, 583 (Colo.1984). In Sundermeyer, we concluded, as had the trial court, that relevant facts had been omitted from an affidavit, but reversed the trial court’s suppression order because no question was raised “as to the truth or the sufficiency of the facts set forth in the affidavit to establish probable cause” and because the omitted facts “were not adverse and ... merely buttressed the facts which supported the issuance of the warrant.” Id. In sharp contrast to the circumstances present in Sundermeyer, the omitted facts here do cast doubt on the truthfulness and sufficiency of the facts contained in Hunt’s affidavit.
In his testimony at the suppression hearing and in his written report Hunt himself recognized that all of the omitted information was relevant to the question of the credibility of C.S.’s statements. Hunt candidly testified that he “heard what I felt to be equal factors on both sides” in consciously determining to omit the disputed facts from his affidavit.3 Determinations of the veracity of information contained in an affidavit for a warrant are to be made by the issuing judge on the basis of “a complete factual predicate.” Winden, 689 P.2d at 582. The magistrate must be given “sufficient facts to permit ... [the] exercise [of] real discretion.” Id. The screening process consciously adopted by Hunt prevented the issuing judge in this case from exercising such discretion.
The majority refers to our decision in People v. Abeyta, 795 P.2d 1324, 1327 (Colo.1990), for the principle that doubts concerning the sufficiency of facts contained in an affidavit to support a judicial determination that the affidavit establishes probable cause should be resolved in favor of such determination “in order to avoid creating a climate in which police resort to warrantless searches rather than obtaining a warrant before conducting a search.” Maj. op. at 1345. In this *1350case the trial court found the affidavit insufficient because it was misleading. The policy expressed in Abeyta is in no manner undercut by the caveat that affidavits submitted in support of search warrants may not be consciously constructed in such fashion as to mislead the issuing judicial officer by means of the omission of relevant facts.
C
The majority emphasizes that “corroboration” of the victim’s statements was not necessary in this case. Maj. op. at 1343, 1344, 1345, 1346, 1347, 1348. The majority also invokes principles developed in citizen-informant cases in support of its conclusion that the trial court erred. In my view, questions of “corroboration” are at best subsidiary to the test applied by the trial court: whether the affidavit was so misleading as to render improper the issuing judge’s probable cause determination. United States v. Leon, 468 U.S. 897, 923, 104 S.Ct. 3405, 3420-21, 82 L.Ed.2d 677 (1984); Unruh, 713 P.2d at 380-81; Winden, 689 P.2d at 583. Accordingly, I find the citizen-informant cases referenced by the majority to be of little assistance in determining the propriety of the trial court’s application of this standard in this ease.
We have long recognized that, absent contrary evidentiary indications, factual reports of citizens who witness or are victims of alleged criminal conduct are presumed to be true. People v. Rueda, 649 P.2d 1106, 1109 (Colo.1982); People v. Ball, 639 P.2d 1078, 1082 (Colo.1982); People v. Henry, 631 P.2d 1122, 1127 (Colo.1981); People v. Hubbard, 184 Colo. 225, 228-29, 519 P.2d 951, 953 (1974); People v. Glaubman, 175 Colo. 41, 50, 485 P.2d 711, 717 (1971). See 2 Wayne R. LaFave, Search & Seizure § 3.4(a) (3d ed. 1996) (“when an average citizen tenders information to the police, the police should be permitted to assume that they are dealing with a credible person in the absence of special circumstances suggesting that such might not be the case_ The ... modem view ... is that as a general proposition any person purporting to be a crime victim or witness may be presumed rehable, though the police must remain alert to the existence of any circumstances which would make that presumption inoperative in a particular case.”) (footnotes omitted). For reasons of sound pubhe pohey, factual reports of anonymous or confidential informants are deemed unreliable in the absence of factual evidence establishing the reliability of the reported facts. Henry, 631 P.2d at 1127; Glaubman, 175 Colo. at 51, 485 P.2d at 716-17; People v. Kurland, 28 Cal.3d 376, 168 Cal.Rptr. 667, 618 P.2d 213, 223 (1980); see United States v. Harris, 403 U.S. 573, 579, 91 S.Ct. 2075, 2079-80, 29 L.Ed.2d 723 (1971). When circumstances indicate that a citizen-informant’s information may be unreliable, just as when facts reported by an anonymous or confidential informer are presumed to be unreliable, courts must determine whether probable cause has been estabhshed by considering the totality of the circumstances. Illinois v. Gates, 462 U.S. 213, 230-31, 103 S.Ct. 2317, 2328-29, 76 L.Ed.2d 527 (1983).
The majority suggests that because C.S. is a citizen-informant, whose factual recitations are presumed true, no corroboration is necessary here. Maj. op. at 1345. The majority also indicates that the evidence omitted from Hunt’s affidavit is not “contrary evidence” requiring determination of the reliability of C.S.’s statements. Maj. op. at 1345-1346.4 However, the issue is not whether corroboration is necessary. Reliability or lack thereof can be estabhshed by many methods. E.g. People v. Pate, 878 P.2d 685, 689-90 (Colo.1994) (sufficient detail, corroboration); People v. Dailey, 639 P.2d 1068, 1072-73 (Colo.1982) (sufficient detail, history of rehable information); People v. Abeyta, 795 P.2d 1324, *13511327 (Colo.1990) (sufficient detail, corroboration); People v. Arellano, 791 P.2d 1135, 1138-39 (Colo.1990) (access to reliable information, sufficient detail, history of providing reliable information). The question posed in this ^ase is whether the information known to Hunt when he executed the affidavit was sufficient information to indicate that the presumption of reliability normally accorded to C.S.’s statements is not available here. I agree with the trial court’s conclusions that the issue of C.S.’s reliability was raised by the testimony concerning the omitted evidence and that under the totality of the circumstances C.S.’s information, absent a presumption of reliability, did not establish probable cause to believe the defendant had engaged in criminal conduct.
D
For the foregoing reasons, I respectfully dissent from the majority opinion.
LOHR, J., joins in this dissent.
. The majority's description of this finding as a “conclusion" is, in my view, erroneous.
. Detective Hunt’s police report contains the following paragraph:
[The father] again was very candid about [C.SJ’s nature and said [C.S.] is capable of fabrication and can be a.very good actor. [The father] described an incident a couple of years ago where [C.S.] had set [the father] up with the Department of Social Services. There had been an episode where [the father] had lightly backhanded [C.S.] in the face and then [C.S.] had used a Crayola to mark his eye up. The next morning it was reported and the Department of Social Services got involved. Later, however, [C.S.] told his counselor at school about making the whole story up. [The father] said having that in mind about [C.S.], he would not be making this report about his suspicions and what [C.S.] has said about Timothy Fortune unless he thought it was true.
[The father] and [his wife] did not have any further relevant information at that time and the interview was concluded....
In view of the People's acceptance of the trial court’s finding that C.S. falsely reported physical abuse, I do not agree with the majorily's conclusion that the record does not support that finding.
. Hunt’s supervisor testified that the omitted facts were relevant to the credibility of C.S. and C.S.'s father testified that he disclosed these facts to the officers because he believed they would help the officer to make “accurate assumption[s] and a proper report.”
. The majority refers to a statement contained in our opinion in People v. Henry, 631 P.2d 1122 (Colo.1981), as the source for the quoted phrase "contrary evidence”:
It is simply unreasonable to presume, in the absence of any contrary evidence, that the ordinary citizen who fortuitously becomes a victim of crime is likely to offer false or untrustworthy information to the police.
Id. at 1127. To the extent the majority finds this "contrary evidence” reference to in some fashion narrow the generality of the “special circumstances" exception early articulated by Glaub-man, I disagree. No formal evidentiary concepts are implied by the exception.