Although Shantel Cline's veracity was never established, her actions, as observed by the police, corroborated what the confidential informant told Officer Bohnert happened. Hearsay can be a proper basis to establish probable cause if there is a substantial basis for crediting the hearsay. Corroboration can occur by independent police work, such as observations of the police themselves. When the confidential informant approached Cline to buy methamphetamine, Cline did not immediately hand over methamphetamine. Instead, the police watched her leave the meeting site, travel directly to the Defendant's residence, travel back to the confidential informant, and only then give the informant methamphetamine.
Common sense is a key ingredient in considering the absence or presence of probable cause.
Based on common sense, Cline's actions alone indicated to the police that the Defendant's house contained methamphetamine. The police investigated the tip, learning the apartment was registered to a Kaylicia Vanee Patrick and observed a green Pontiac parked at the apartment. The officer also learned that the defendant had been previously arrested for selling cocaine from the same apartment and possession of cocaine. Based on this information, the court found probable cause to issue and issued a search warrant for the apartment. The Western District found the hearsay statements in the anonymous tip had been corroborated by independent police observations, which created a substantial basis for crediting the hearsay contained in the affidavit.