Cited by

(evaluating reliability of an informant’s tip to police in a criminal case, noting that an informant’s credibility may be “enhanced because the informant is presumably aware that he or she could be arrested for making a false report”).

A tip may be reliable if it is based on “[r]ecent personal observation of incriminating conduct,” which is typically “the preferred basis for an informant’s knowledge.”

T he court “must make a common-sense determination based on practical considerations of everyday life and the individual circumstances of each case.” (quotation omitted).

Finally, the affidavit notes that law enforcement independently observed “come and go traffic at Dueck’s residence,” and that the “traffic includes known drug users and or dealers.” See Wiggins, d at 147 (“If part of an informant’s tip may be corroborated by police as truthful, that tends to suggest that the entire tip may be truthful.”); (noting that corroboration “of even minor details can lend credence to the informant’s information where the police know the identity of the informant” (quotat

Nexus Between the Facts in the Search-Warrant Affidavit and the Contraband Sought at Hinton’s Apartment Hinton argues that the CRI’s information “did not provide a nexus to contraband at [Hinton’s] apartment,”

may probably be found at the present time.” ( rev. denied (Minn. Jan.

- 72 (Minn. App. 1998) ().

Jones further contends that “[a]t least three of the Ross factors weighed against reliability, while two others were of neutral utility given their lack of information.” Jones refers to this court’s which cited our opinion in State v. Ward

While informants are minimally more reliable if they make a statement against their own interest, “courts remain reluctant to believe the typical ‘stool pigeon’ who is arrested and who, at the suggestion of the police, agrees to cooperate and name names in order to curry favor with the police.” State v. Ward , -72 (Minn. App. 1998).

(d 67, 71 (Minn. App. 1998)), review denied (Minn. June 15, 2004).

A probable-cause determination “is limited to the information contained in the affidavit offered in support of the warrant application.”

A first-time citizen informant is presumed reliable when they have “not been involved in the criminal underworld.”

“Probable cause has been defined variously as the objective facts that under the circumstances would cause a person of ordinary care and prudence to entertain an honest and strong suspicion that a crime has been committed.” (quotations omitted).

“In general, a single incident of criminal activity, such as a sale of contraband, ‘will support a finding of probable cause only for a few days at best.’” ( (citation omitted)).

“Probable cause has been defined various ly as the objective facts that under the circumstances would cause a person of ordinary care and pruden ce to entertain an honest and strong suspicion that a crime has been committed.” (quotations omitted).

“[C]orroboration of even minor details can lend credence to the inf ormant’s information where the police know the identity of the informant.” State v. Ward , (quotation omitted).

“Where a probable cause determination is based on an informant’s tip, the informant’s veracity and the basis of his or her knowledge are considerations under the totality test.”

“[C]orroboration of even minor details can lend credence to the informant’s information where the police know the identity of the informant.” (quotation omitted).

will support a finding of probable cause only for a few days at best,” (quotation omitted).

As to the fourth reliability factor, that an informant is presumably more reliable if the informant voluntarily comes forward, Palmer argues that because the CRI was paid 12 $600 for the tip, the CRI’s “reliability was sig nificantly diminis hed.” Palmer relies on State v. Ward , asserting that the payment “effectively branded the informant a ‘stool pigeon.’” Ward states that “courts remain reluctant to believe the typical ‘stool pigeon’ who is arrested and who, at the suggestion of the police,

ation and investigation established reasonable, articulable suspicion that Vagle was engaged in narcotics activities.” “An informant’s reliability may be established by sufficient police corroboration of the information supplied, and corroboration of even minor details can ‘ lend credence’ to the informant’s information where the police know the identity of the informant.” .

“Where a probable cause determination is based on an informant’s tip, the informant’s veracity and the basis of his or her knowledge are considera tions under the totality test.” State v. Ward

(stating that court of appeals is “not in position to overturn established supreme court precedent”).

(using “veracity” and “reliability” interchangeably).

In such cases, “the informant’s veracity and the basis of his or her knowledge are considerations under the totality test.” .

If a probable-cause determination is based on an informant’s tip, “the informant’s veracity and the basis of his or her knowledge are considerations under the totality test.”

“Where a probable cause determination is based on an informant’s tip, the informant’s veracity and the basis of his or her knowledge are considerations under the totality [of the circumstances] test.” State v. Ward

(“[W]e are not in position to overturn established supreme court precedent.”) (citations omitted).

(“[W]e are not in position to overturn established supreme court precedent.”).

(concluding that when “controlled purchase” is not used in an affidavit by an experienced drug enforcement officer, it was not a proper controlled purchase).

(“An informant’s reliability may be established by sufficient police corroboration of the information supplied, and corroboration of even minor details can ‘lend credence’ to the informant’s information where the police know the identity of the informant.”).

(“[W]e are not in position to overturn established supreme court precedent.”) (citations omitted).

–72 (Minn. App. 1998) (“[C]ourts remain reluctant to believe the typical ‘stool pigeon’ who is arrested and who, at the suggestion of the police, agrees to cooperate and name names in order to curry favor with the police.” (alteration omitted) (quotation omitted)).

See, review denied (Minn. June 16, 2004)

“[A]n informant’s reliability may be demonstrated where the informant has previously given police correct information, but the affidavit must explicitly state this to be the case.”