State v. Maxwell

778 P.2d 51, 55 Wash. App. 446, 1989 Wash. App. LEXIS 295
CourtCourt of Appeals of Washington
DecidedAugust 29, 1989
DocketNo. 9375-1-III
StatusPublished
Cited by2 cases

This text of 778 P.2d 51 (State v. Maxwell) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Maxwell, 778 P.2d 51, 55 Wash. App. 446, 1989 Wash. App. LEXIS 295 (Wash. Ct. App. 1989).

Opinions

Shields, J.

The trial court suppressed evidence obtained pursuant to the execution of a search warrant and dismissed the State's prosecution of Edward A. Maxwell, presumably for manufacturing marijuana. The State appeals, contending the credibility of the informant was established as well as the reliability of his information and that the information in the affidavit established probable cause, not mere suspicion. We reverse and remand for trial.

The affidavit1 stated that the affiant, a member of the Tri-Cities Metro Drug Unit, had received information from [449]*449a citizen/neighbor informant regarding activities at a rental house at 4103 S. Kent. During a period of several months, the neighbor had personally observed two male subjects show up for short periods of time, unload their trailer in a closed garage, then leave. He reported the windows were covered with foil and the presence of three vehicles: a dark Chevrolet pickup, an old El Camino and a Chevrolet Nova. The citizen also overheard two subjects state "If we ever get caught doing this, we will be in prison forever."

The affiant attempted to corroborate the information provided by the citizen. He maintained surveillance of the property and reported the grass was dry and uncut, no garbage service was used and that the electrical usage was high for a residence that was unoccupied. He also identified the cars, and learned they were registered to Mr. Maxwell, David Bruises, and the third, described as a Nova but actually a Dodge, was registered to Ann F. Thorselt of Puyallup, Washington. Mr. Bruises was additionally described as having been charged in Oregon with manufacturing marijuana and pleaded guilty to possession of less than 1 ounce in 1978. Certain other stipulated facts were also before the trial court.2

[450]*450The trial court, in suppressing the evidence, questioned the lack of underlying facts to establish the credibility of the informant, stating his identity alone was insufficient under State v. Lair, 95 Wn.2d 706, 630 P.2d 427 (1981). It also found certain inconsistencies in the facts reported by the neighbor, so reasoned they did not meet the reliability prong of Aguilar-Spinelli.3 It disputed the basis for the conclusion the electrical usage was abnormally high, noting the law requires an identification of the person rendering that opinion. Finally, the court concluded the activities were nothing more than suspicious activity and held the affidavit was legally insufficient to establish probable cause to believe criminal activity was occurring.

We first address whether the affidavit sufficiently met the requirements of Aguilar-Spinelli.

It is well settled:

When an informant's tip forms the basis for a search warrant, the affidavit in support of the warrant must establish the basis of information and credibility of the informant in order to [451]*451evaluate the existence of probable cause. State v. Jackson, 102 Wn.2d 432, 433, 688 P.2d 136 (1984); see Spinelli v. United States, 393 U.S. 410, 21 L. Ed. 2d 637, 89 S. Ct. 584 (1969); Aguilar v. Texas, 378 U.S. 108, 12 L. Ed. 2d 723, 84 S. Ct. 1509 (1964).

State v. Franklin, 49 Wn. App. 106, 107-08, 741 P.2d 83, review denied, 109 Wn.2d 1018 (1987). The two prongs of the Aguilar-Spinelli test have independent status and both are required to establish probable cause. State v. Jackson, 102 Wn.2d 432, 437, 688 P.2d 136 (1984). However, if the informant's tip fails under either or both of the prongs, probable cause may be established by independent police investigation that "corroborates the tip to such an extent that it supports the missing elements of the Aguilar-Spinelli test." Jackson, at 438.

The trial court first concluded the credibility prong of Aguilar-Spinelli was not satisfied. However, the court overlooked the fact this was a known citizen informant, uninvolved in the activity next door. Given these circumstances, different rules apply. In State v. Rodriguez, 53 Wn. App. 571, 574-75, 769 P.2d 309 (1989), the court observed:

When police receive information from an uninvolved witness or victim of a crime, the necessary showing of credibility is relaxed. State v. Northness, 20 Wn. App. 551, 556, 582 P.2d 546 (1978). . . .
[W]hen an average citizen tenders information to the police, the police should be permitted to assume that they are dealing with a credible person in the absence of special circumstances suggesting that such might not be the case. . . .
. . . The . . . modern view ... is that as a general proposition any person purporting to be a crime victim or witness may be presumed reliable, . . . Thus, courts frequently emphasize, in the course of holding that veracity was properly presumed, that the police were unaware of any "apparent motive to falsify" or that it did not appear to the police "that the accusations by the citizen were reported to the police merely to spite defendant." . . .
(Footnotes omitted.) 1 W. LaFave, Search and Seizure § 3.4(a), at 718-20 (2d ed. 1987).

Mr. Maxwell relies on State v. Lair, supra, which considered the reliability of a named informant who had delivered quantities of marijuana to the defendant. Lair, at 712 [452]*452(citing State v. Sieler, 95 Wn.2d 43, 48, 621 P.2d 1272 (1980)), held "[t]o the extent that the informant's name is the only information claimed to support his or her veracity, we have recently held that a mere name is insufficient." Lair can be distinguished, however, because it involved a person other than a citizen informant who was involved in the delivery of marijuana. Those facts are not present here. The informant's name was provided to the police and the magistrate, he was an uninvolved neighbor, and had obtained his information by firsthand observation conducted in an unsuspicious manner. Thus we conclude credibility was established.

The court also questioned the basis of knowledge prong, noting discrepancies in the number of windows which were actually covered with foil and the incorrect identification of one of the cars observed at the scene. As noted in State v. Smith, 110 Wn.2d 658, 663, 756 P.2d 722 (1988), cert. denied,_U.S._, 102 L. Ed. 2d 991, 109 S. Ct. 867 (1989); Rodriguez, at 574 (citing State v. Jackson, supra at 437), to satisfy the basis of knowledge test, the informant may state he has observed the facts personally and is passing on firsthand knowledge.

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Related

State v. Ibarra
812 P.2d 114 (Court of Appeals of Washington, 1991)
State v. Maxwell
791 P.2d 223 (Washington Supreme Court, 1990)

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778 P.2d 51, 55 Wash. App. 446, 1989 Wash. App. LEXIS 295, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-maxwell-washctapp-1989.