Garner v. State

314 A.2d 908, 1973 Del. LEXIS 292
CourtSupreme Court of Delaware
DecidedSeptember 14, 1973
StatusPublished
Cited by32 cases

This text of 314 A.2d 908 (Garner v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garner v. State, 314 A.2d 908, 1973 Del. LEXIS 292 (Del. 1973).

Opinions

HERRMANN, Chief Justice:

The defendant, James Garner, seeks review of his conviction for robbery. The question presented is whether the State may avoid revealing the substance of an informant’s tip upon the basis of which an arrest was made, there being no other basis for a finding of probable cause for the arrest.

T.

The victim was robbed by a man wearing a stocking mask. Although unaware of the robber’s identity, the victim was able to identify William E. Smith, the other defendant in the case, as being present at the scene of the robbery. A search for Smith was begun.

A few days later, a police officer received a tip from an unidentified informant that Garner was the masked robber and that Garner and Smith would be at a certain street corner at a particular time. The informant described the car and the route the men would be taking. Pursuant to that tip, the men were apprehended. At a line-up, the victim identified Garner as the robber. At trial, the arresting officer testified to the above facts and the informant’s known reliability, but refused to testify as to what facts were related to him by the informant which would support the allegation that Garner was the robber. The police officer stated, as his reason for declining so to testify, that he was obliged to protect the identity of the informant; that revelation of the substance of the tip would, ipso facto, disclose the identity of the informant.

The victim made an in-court identification of Garner, but it was based solely upon the line-up identification. From his conviction, Garner appeals.

II.

We agree with the defendant that probable cause for his arrest was not shown. When measured against constitutional standards, there was insufficient corroboration of the informant’s statements that the defendant was involved in the crime. Specifically, there was no showing as to how the informant acquired his information ; nor was there a showing, with constitutional sufficiency, of the basis for believing that the information was reliable. Aguilar v. Texas, 378 U.S. 108, 84 S.Ct. 1509, 12 L.Ed.2d 723 (1964); Beck v. Ohio, 379 U.S. 89, 85 S.Ct. 223, 13 L.Ed.2d 142 (1964); Spinelli v. United States, 393 U.S. 410, 89 S.Ct. 584, 21 L.Ed.2d 637 (1969); United States v. Harris, 403 U.S. 573, 91 S.Ct. 2075, 29 L.Ed.2d 723 (1971).

The law requires for all valid arrests, with or without warrants, that police officers possess information which would warrant a reasonable man in believing that a crime had been committed. Beck v. Ohio, 379 U.S. 89, 85 S.Ct. 223, 13 L.Ed.2d 142 (1964); Brinegar v. United States, 338 U.S. 160, 69 S.Ct. 1302, 93 L.Ed. 1879 (1949). The determination of whether such probable cause exists is essentially a balancing test wherein the necessities of effective law enforcement are measured [911]*911against the constitutional rights of citizens to be protected against arbitrary police action. Brinegar v. United States, supra (69 S.Ct. at 1311).

Probable cause can be established from either direct observation or hearsay. The latter, consisting generally of incriminatory reports to the police by informants or witnesses, is acceptable, provided that it is sufficiently corroborated by other facts within the officer’s knowledge. Draper v. United States, 3S8 U.S. 307, 79 S.Ct. 329, 3 L.Ed.2d 327 (1959); Aguilar v. Texas, 378 U.S. 108, 84 S.Ct. 1509, 12 L.Ed.2d 723 (1964); Spinelli v. United States, 393 U.S. 410, 89 S.Ct. 584, 21 L.Ed.2d 637 (1969). While the use of informants in the fight against crime has become a pragmatic imperative of modern law enforcement, the use of such information -is circumscribed by the Fourth Amendment to the extent that it must be reliable. The problem is one of gauging the quantum of evidence necessary to support such reliability.

To measure something as elusive of concrete definition as “reliability” is, of course, a difficult task; the boundaries of the term cannot be drawn with any great degree of precision. It is certain, however, that a bare statement of the belief of a police officer, as to the reliability of an unnamed informant and the truthfulness of his statements, is not sufficient basis for a judicial accreditation of the report of such informant as “reliable” within the constitutional guaranty. United States v. Harris, 403 U.S. 573, 91 S.Ct. 2075, 29 L.Ed.2d 723 (1971). Similarly, a bare statement that the information came from a “creditable source” is insufficient. Spinelli v. United States, 393 U.S. 410, 89 S.Ct. 584, 21 L.Ed.2d 637 (1969). Generally, an informant’s information, though not necessarily his identity, must be divulged in the establishment of probable cause. Roviaro v. United States, 353 U.S. 53, 77 S.Ct. 623, 1 L.Ed.2d 639 (1957); McCray v. Illinois, 386 U.S. 300, 87 S.Ct. 1056, 18 L.Ed.2d 62 (1967). This is essential to the tests of relevancy and reliability by the trial court and to the review of those essentials by an appellate court.

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314 A.2d 908, 1973 Del. LEXIS 292, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garner-v-state-del-1973.