California, United States of America
The following excerpt is from People v. Barraza, H045987 (Cal. App. 2019):
The Attorney General argues that the information related by the informant based on his personal knowledge " 'may compensate for a less than conclusive demonstration of credibility,' " citing People v. French (2011) 201 Cal.App.4th 1317. The probable cause affidavit found deficient in French relied on information provided by several confidential informants. Addressing a hearsay statement by one of the informants (that his wife had purchased heroin from the defendant), the court in French commented that "hearsay has little value where the informant is untested and the information is uncorroborated and lacking in detail." (Ibid.) Indeed, the affidavit in French was facially deficient because none of the informants was inherently reliable (a statement that past information given by an informant " 'was corroborated and criminal cases were made behind the information' " was found insufficient to establish reliability); none provided significant information based on personal knowledge; the police investigation corroborated only pedestrian facts; and a criminal history lacking detail was not corroborative. (Id. at pp. 1316-1321.)
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