In Munson , the details corroborated after the stop but before the search included the type, year, and color of the vehicle, the fact that it was registered to a rental agency, its destination, the timing of its arrival, and the identity of its occupants. On this basis, the supreme court held that the corroborated details of the informant s tip, as well as the past reliability of the informant, gave the police probable cause to believe that the vehicle was carrying contraband and justified the search. Here, the police did not have vehicle registration information, and the informant knew Harris only by a nickname. But before the search, the police corroborated the type, year, and color of the car, and the informant identified the driver. Also, Monjeau s observation of Harris s right hand dropping from the steering wheel to his side near the console provided additional factual information that helped establish probable cause to search the Toyota.
Furtive gestures can provide a basis for probable cause.
The Munoz court determined that a suspect who leaned so far to the passenger side of the vehicle as to be barely visible was likely concealing either contraband or a weapon. But in Cook , the information the informant provided police could have been easily obtained by anyone, not just by someone with inside knowledge of the suspect s activities. Here, the fact that Harris would arrive at a specific grocery store on a specific day was not information that could be easily obtained by the general public, and therefore, demonstrated that the informant had inside knowledge of Harris s activities. Reversed and remanded.