Cited by

Id.; -04 (Minn. 1990); d 179, 181 & n.1 (Minn. 1986).

at 892; (concluding that warrant was supported by probable cause where informant observed contraband two days before issuance of warrant); 703 (Minn. 1990) (concluding that warrant was supported by probable cause where informant reported observing narcotics at residence within the preceding week).

” (quoting Illinois v. Gates, 462 U.S. 213, 238 (1983) ).

actical, common-sense decision whether, given all the circumstances set forth in the affidavit before him, including the ‘veracity’ and ‘basis of knowledge’ of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place.” -03 (Minn. 1990) (quoting Gates, 462 U.S. at 238).

[T]he magistrate’s task is “simply to make a practical, common-sense decision whether, given all the circumstances set forth in the affidavit before him, including the ‘veracity’ and ‘basis of knowledge’ of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place.” (quoting Gates, 462 U.S. at 238).

The “resolution of doubtful or marginal cases should be largely determined by the preference to be accorded to warrants.” (quotation omitted).

(explaining that courts “recognize[] that each informer is different and that all of the stated facts relating to the informer should be considered in making a totality-of-the-circumstances analysis”); d 532, 540- 42 (Minn. App. 2005) (distinguishing between con

(explaining that courts “recognize[] that each informer is different and that all of the stated facts relating to the informer should be considered in making a totality-of-the-circumstances analysis”); (distinguishing concerned citizens fro

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

The informant’s prior collaboration enhances the veracity of the tip because it puts the informant in “a position to be held accountable.” - 07 (Minn. 1972).

(d 700, 704 (Minn. 1990)).

’” (), review denied (Minn. July 25, 2000).

See State v. McCloskey , d 700, 702, 704 (Minn. 1990) (holding that an eight-y ear-old DWI arrest, a probation violation warrant, a warrant for expired pl ates, and a warrant for speeding constituted “relatively minor trouble with the law [that] was perhaps of some slight probative value” toward a probable-cause determination).

“The less rigid approach of Gates recognizes that each informer is different and that all of the stated facts relating to the informer should be considered in ma king a totality-of-the-circumstances analysis.”

“[T]he resolution of doubtful or marginal cases should be ‘largely determined by the preference to be accorded to warrants.’” (quoting United States v. Ventresca, 380 U.S. 102, 109, 85 S. Ct. 741, 746 (1965)).

Also, the fact that an informant makes a statement against his or her own interest “is of some minimal relevance in a totality-of-the-circumstances analysis.”

We defer to the issuing magistrate, recognizing that “doubtful or marginal cases should be ‘largely determined by the preference to be accorded to warrants.’ ” (quoting United States v. Ventresca, 380 U.S. 102, 109 , 85 S.Ct.

The fact that an informant made a statement against his or her own interest “is of some minimal relevance in a totality-of-the- circumstances analysis of probable cause.”

Caselaw provides that an informant’s statement against his interest “establishes reliability only when combined with another factor, such as corroboration.” See Ward, d at 72; (concluding that the “mere fact that the statement was in some way against the informant’s interest is of some minimal relevance in a totality-of-the-circumstances analysis of probable cause”).

791 n. 1 (Minn.1999); , 864 n. 4 (Minn.1991); , 701 n. 1 (Minn.1990); , 269 n. 2 (Minn.1985); , 929 n. 7 (Minn.2006) (resolving the issue on statutory grounds and declining to consider the good-faith exception articulated in Hudson v. Michigan, 547 U.S. 586 , 126 S.Ct.

Searches conducted pursuant to a warrant are strongly preferred, and “doubtful or marginal cases should be largely determined by the preference to be accorded to warrants.” (quotation omitted).

See Souto, d at 750–51 (concluding that an “informant’s reliability was satisfactorily established” where the informant met with 11 police “face-to-face and made admissions against his own interest” and where “information provided by the informant was corroborated by [police]”); (stating that “[t]he mere fact that the statement was in some way against the informant’s interest is of some minimal relevance in a totality-of-the-circumstances analysis of probable cause,” that “the fact the informant

The “doubtful or marginal cases [will be] largely determined by the preference to be accorded to warrants.” (quoting United States v. Ventresca, 380 U.S. 102, 109, 85 S. Ct. 741, 746 (1965)) (quotation marks omitted).

But the totality- of-the-circumstances approach “recognizes that each informer is different and that all of the stated facts relating to the informer should be considered.”