State v. Carlson

Judge LANSING,

Dissenting.

I respectfully dissent. In my view, the majority opinion ignores several features of the warrant affidavit which, when examined in light of controlling constitutional standards, render the affidavit insufficient to show probable cause. These important elements include the anonymity of the informant, the omission of the age of some of the information provided by an officer, and the inclusion of unsubstantiated rumor and suspicion.

In Illinois v. Gates, 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983), the United States Supreme Court adopted a “totality of the circumstances” test for the review of a magistrate’s finding of probable cause. Prior to Gates, two United States Supreme Court decisions, Spinelli v. United States, 393 U.S. 410, 89 S.Ct. 584, 21 L.Ed.2d 637 (1969) and Aguilar v. Texas, 378 U.S. 108, 84 S.Ct. 1509, 12 L.Ed.2d 723 (1964), mandated a more restrictive two-pronged test in cases where the warrant application rested upon hearsay information from an informant. This test required that the government show the veracity or reliability of the informant and the basis of the informant’s knowledge. Spinelli, 393 U.S. at 413, 89 S.Ct. at 587, 21 L.Ed.2d *479at 641; Aguilar, 378 U.S. at 113-115, 84 S.Ct. at 1513-1514, 12 L.Ed.2d at 727-729. The veracity of the statements could be demonstrated either through the general credibility of the informant or through the reliability of the specific information provided. The basis of the informant’s knowledge could be shown either directly, by a statement describing the circumstances under which the informant obtained his or her information, or indirectly, by including enough detail that the information in the report became self-verifying. Id.; State v. Chapple, 124 Idaho 525, 528, 861 P.2d 95, 98 (Ct.App.1993). Although the “totality of the circumstances” test of Gates replaced the Aguilar-Spinelli inquiry, the two-pronged test remains “highly relevant in determining the value of [an informant’s] report.” Gates, 462 U.S. at 230, 103 S.Ct. at 2328, 76 L.Ed.2d at 543. Thus, this Court has applied the Aguilar-Spinelli inquiry as “a useful first step in evaluating probable cause where the information is derived, at least in part, from an undisclosed informant.” State v. Schaffer, 107 Idaho 812, 817, 693 P.2d 458, 463 (Ct.App.1984). See also State v. Peterson, 133 Idaho 44, 981 P.2d 1154 (Ct.App.1999); State v. Wengren, 126 Idaho 662, 667, 889 P.2d 96, 101 (Ct.App.1995); Chapple, supra; State v. McAndrew, 118 Idaho 132, 134, 795 P.2d 26, 28 (Ct.App.1990); State v. Vargovich, 113 Idaho 354, 355-56, 743 P.2d 1007, 1008-09 (Ct.App. 1987).

I readily agree with the majority opinion that the “basis of knowledge” prong is satisfied in the present case, for Sergeant Chatterton’s affidavit indicates that the informant claimed to have personally observed marijuana in the Carlson residence. However, there is a complete absence of information to satisfy the veracity prong, i.e., to show that the informant was a credible source. So far as the affidavit reveals, the informant provided the tip anonymously. There is no indication in the affidavit that Sergeant Chatterton knew the identity of the informant, that the police had previously received truthful information from the informant, or that Sergeant Chatterton had any reason to believe the informant to be reliable and credible. Hence, the informant in this ease must be viewed as anonymous and lacking any presumption of reliability.

The lack of any showing of the informant s reliability requires an examination of the affidavit to determine whether information from other sources corroborates the informant’s report of a marijuana growing operation or otherwise independently provides probable cause for the warrant. The affidavit states that police officers confirmed the informant’s description of the exterior layout of the Carlson property. However, so far as can be discerned from the affidavit, all of the descriptive information could be observed from the street by any passerby, and thus the accuracy of the informant’s description of the exterior details did not tend to confirm that the informant had been inside the Carlson home or garage as claimed. The details that were corroborated were innocuous and not indicative of illegal behavior.

The information from Undersheriff Roberts indicated that “some time ago” she had been involved in a case in which a juvenile suspect claimed that the marijuana in his possession had been obtained from a juvenile male who lived at the Carlson address. Undersheriff Roberts also reported that she had heard from another boy’s parent that the boy owed $500 to the juvenile living in the Carl-sons’ home for the purchase of marijuana. This information might have been sufficient to provide probable cause if there had been some indication that the information was current enough to be relevant. The term “some time ago” implies that the event did not occur in the immediate past. It could indicate a time frame from a few weeks to several years ago. To satisfy the constitutional probable cause standard, evidence must create probable cause for the belief that the items sought are at the place to be searched “at the time the search warrant is requested.” Josephson, 123 Idaho at 794, 852 P.2d at 1391 (quoting State v. Gomez, 101 Idaho 802, 808, 623 P.2d 110, 116 (1980)). Information which, through the passage of time, has grown too stale to be relevant will not satisfy this standard. See Josephson, 123 Idaho at 794-95, 852 P.2d at 1391-92 (holding that the discovery of marijuana and paraphernalia during a search of the defendant’s garbage that reportedly occurred one month before the application for the warrant was too stale to provide probable cause to *480believe marijuana would be found in the defendant’s house.) I acknowledge that information which indicates a continuous criminal activity, such as drug trafficking, does not become stale as rapidly as information suggesting sporadic or occasional illegal acts. Josephson, 123 Idaho at 794, 852 P.2d at 1391; State v. Thompson, 113 Idaho 466, 479 n. 10, 745 P.2d 1087, 1100 n. 10 (Ct.App.1987), rev’d in part on other grounds, 114 Idaho 746, 760 P.2d 1162 (1988). Nonetheless, as our Supreme Court stated in State v. Oropeza, 97 Idaho 387, 392, 545 P.2d 475, 480 (1976), with respect to a reported drug transaction, “some particularity as to time must be made so as to enable the magistrate to make his determination of present probable cause for the issuance of the search warrant.” Here, the complete absence of any indication of the age of the information severely limits its probative value.

The remaining information reported in Sergeant Chatterton’s affidavit was mere unsubstantiated rumor or suspicion bearing no indicia of accuracy. The United States Supreme Court has said that “just as a simple assertion of police suspicion is not itself a sufficient basis for a magistrate’s finding of probable cause, we do not believe it may be used to give additional weight to allegations that would otherwise be insufficient.” Spinelli, 393 U.S. at 418-419, 89 S.Ct. at 590, 21 L.Ed.2d at 645. Hence, Sergeant Chatterton’s affidavit contained neither information demonstrating the unnamed informant’s veracity nor any creditable, demonstrably non-stale information tending to corroborate the informant’s allegations.

I find this ease indistinguishable from others where the Idaho appellate courts have held that a tip from an anonymous informant, without significant corroboration, is insufficient to establish probable cause. For example, in Schaffer, supra, this Court held that probable cause was not established by evidence that the sheriff had received two telephone calls from an anonymous tipster asserting that the defendant was growing marijuana in a greenhouse, the defendant’s family was rumored to be dealing in marijuana, and the sheriff had confirmed that the home had a greenhouse which appeared to contain tall plants but could not discern whether the plants were marijuana. Similarly, in Josephson, supra, the Idaho Supreme Court held that probable cause was not demonstrated where an anonymous telephone caller reported seeing marijuana plants through the open door of an outbuilding on the defendant’s property and stated that the defendant received a large number of visitors at his residence. The warrant affidavit also indicated that, one month previously, officers searching the defendant’s garbage had found marijuana cigarette butts, leftover stems, a bag with marijuana residue, and an empty pack of rolling papers.

More recently, we considered an affidavit that related an unnamed informant’s claim that the informant had observed paraphernalia in the defendant’s house, had been told that there were marijuana plants upstairs, and had observed a small plant, resembling a tomato, growing upstairs in the house. The affidavit also related that an officer had personally observed lights on all night in the upper story of the defendant’s house. We concluded that the evidence did not demonstrate probable cause for a search warrant. State v. Turpin, 129 Idaho 748, 932 P.2d 376 (Ct.App.1997).

As in Schaffer, Josephson and Turpin, the anonymous informant’s tip here was insufficiently supported by evidence of the informant’s veracity or corroborating investigation to support a finding of probable cause. Aside from the informant’s allegations, the affidavit presented only rumor, confirmation of the informant’s description of innocent details about the defendants’ residence that could be observed from outside the property, and information about alleged marijuana sales that was of unspecified age and therefore of unknown relevance. This information did not provide a substantial basis for a finding of probable cause. Therefore, in my view, the defendants’ motions for suppression of the evidence found in execution of the warrant should have been granted.