State v. Rigsbee

233 N.W.2d 312, 89 S.D. 360, 1975 S.D. LEXIS 155
CourtSouth Dakota Supreme Court
DecidedSeptember 19, 1975
DocketFile 11389
StatusPublished
Cited by9 cases

This text of 233 N.W.2d 312 (State v. Rigsbee) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Rigsbee, 233 N.W.2d 312, 89 S.D. 360, 1975 S.D. LEXIS 155 (S.D. 1975).

Opinions

DOYLE, Justice

(dissenting).

As stated in the majority opinion, the defendant Rigsbee was arrested by officers of the Watertown Police Department on information that “ ‘Mr. Rigsbee had marijuana or a controlled substance in his vehicle and he normally went to the Club 20 between 6:20 and 7:00, and * * * that he had been selling marijuana out there.’ ” Upon this meager information, it is contended that probable cause existed for the arrest of the defendant.

In dealing with probable cause based partially on an informant’s tip, the United States Supreme Court has said:

“The informer’s report must first be measured against Aguilar’s standards so that its probative value can be assessed. If the tip is found inadequate under Aguilar, the other allegations which corroborate the information contained in the hearsay report should then be considered.” Spinelli v. United States, 1969, 393 U.S. 410, 415, 89 S.Ct. 584, 588, 21 L.Ed.2d 637, 643.1

In Aguilar v. Texas, 1964, 378 U.S. 108, 84 S.Ct. 1509, 12 L.Ed.2d 723, an informant’s tip used to secure a search warrant was measured against the following test:

“[T]he magistrate must be informed of some of the underlying circumstances from which the informant con-[369]*369eluded that the narcotics were where he claimed they were, and some of the underlying circumstances from which the officer concluded that the informant * * * was ‘credible’ or his information ‘reliable.’ ” 378 U.S. at 114, 84 S.Ct. at 1514, 12 L.Ed.2d at 729. (emphasis supplied)

The second Aguilar criterion, as noted in the majority opinion, is not in question here. Defendant concedes the reliability of the informant, and absent such a concession I would reach the same result. This informant had been used before and had been instrumental in several arrests and convictions. Cf. McCray v. Illinois, 1967, 386 U.S. 300, 87 S.Ct. 1056, 18 L.Ed.2d 62; Walker v. Nelson, 1972, 9 Cir., 468 F.2d 451.

However, just as surely as this tip passes one of Aguilar’s tests, it fails the other. The record is totally void of any “underlying circumstances” that would tell a magistrate or this court why the informant believed defendant had the marijuana. This is a reasonable requirement and it is one this court should not be willing to forsake for the expediencies of law enforcement. The Fourth Amendment favors the use of a warrant and the standard of probable cause to “assure that the judgment of a disinterested judicial officer will interpose itself between the police and the citizenry.” Spinelli v. United States, 1969, 393 U.S. 410, 419, 89 S.Ct. 584, 591, 21 L.Ed.2d 637, 645. When, because of the practicalities of law enforcement, an arrest is made without a warrant, a court acting after the fact must be able to. determine whether probable cause existed. If there was probable cause, the arrest will be upheld. If probable cause did not. exist, the arrest becomes a nullity. In either case, the constitutional protections guaranteed the citizenry are left intact. The decision to arrest may be made by the police, but the determination of probable cause still belongs to the courts.

When, however, an informant relates only that a crime will be committed and does not tell how he reached this conclusion, the courts are precluded from performing their constitutional duty — the determination of probable cause. Informants, regardless of their reliability, are capable of drawing unjustified conclusions. Personal observation would obviously be enough to [370]*370affirm the informant’s conclusion, but I am presented with none of the “underlying circumstances” available to the informant in this case. I am unable to determine whether the informant was basing his conclusion on probable cause, and I refuse to delegate that function to a non-judicial officer. The informant’s tip must be held inadequate.

Finding the tip insufficient, I must now follow the instructions of Spinelli v. United States, supra, to determine whether the insufficient tip can be teamed with any independent corroboration to reach the sum of probable cause. The only other facts at hand are Officer Durham’s knowledge of defendant’s record and the informant’s assertion that Rigsbee would be traveling to a certain place at a certain time.

The state cites United States v. Harris, 1971, 403 U.S. 573, 91 S.Ct. 2075, 29 L.Ed.2d 723, for the proposition that knowledge of a previous record can cure a tip not meeting the first Aguilar test. I do not read Harris in this manner. Harris’ conviction had been reversed in the court of appeals because “there was no substantial basis for believing that the tip was truthful.” 403 U.S. at 579, 91 S.Ct. at 2080, 29 L.Ed.2d at 731. Harris centered on this issue. The question was whether the informant could be believed, a basic requirement of Aguilar. The United States Supreme Court merely held that when an informer’s tip is deficient in the truth department, the policeman’s knowledge of the defendant’s record, while perhaps not sufficient, is certainly relevant to the believability of the tip. In Harris v. United States, supra, the tip was found sufficient under Aguilar.2

The case at hand, however, is entirely different. The truthfulness of the informant is not in doubt, it is the wisdom of his conclusion that is questioned here. The fact that Officer Durham knew about defendant’s previous record really says [371]*371nothing about whether the informant had probable cause to believe Rigsbee possessed a controlled substance — the other branch of the Aguilar test.

Independent corroboration may, however, be used in another manner. Draper v. United States, 1959, 358 U.S. 307, 79 S.Ct. 329, 3 L.Ed.2d 327, is the classic example of this. There the additional information given the police by the informant was so detailed that although the basis for the informant’s conclusion was missing, the sheer weight and detail of those extra facts gave the police probable cause to arrest once the facts were confirmed by police observation.

The basis of this approach is, I believe, that when the police have enough outside information, whether from the informer or otherwise, to believe that the informer knows so much about the suspect to have probable cause for his conclusion, the police also have probable cause. Here we have only Rigsbee’s previous record and the statement that Rigsbee would be traveling a certain road at a certain time. This hardly compares to the detailed description in Draper v. United States, supra; and, assuming Harris was using independent corroboration in this manner, the extra information available to the police in that case far outweighs the information present here. In

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State v. Rigsbee
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Cite This Page — Counsel Stack

Bluebook (online)
233 N.W.2d 312, 89 S.D. 360, 1975 S.D. LEXIS 155, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-rigsbee-sd-1975.