This Court reversed, finding the affidavit was insufficient to show probable cause because the veracity of the informant's wife, the other lady and the defendant's mother had not been established. After reviewing the affidavit, we find the issuing judge had a substantial basis for concluding probable cause existed to issue the warrant. Here, we do not have uncorroborated fourth-hand hearsay as in Hammett. 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.