California, United States of America
The following excerpt is from People v. Lazanis, 209 Cal.App.3d 49, 257 Cal.Rptr. 180 (Cal. App. 1989):
The case which first considered the problem of an arrest or detention based upon a communication from one police officer to another is Whiteley v. Warden (1971) 401 U.S. 560, 91 S.Ct. 1031, 28 L.Ed.2d 306. The factually complicated situation developed in this fashion: a Wyoming police officer received a radio alert issued by the sheriff of another county which caused him to stop the defendant's car and arrest the occupants. The radio bulletin was based upon an arrest warrant which a justice of the peace had issued predicated upon information which the sheriff had supplied. A search of the car disclosed the presence of old coins and tools which comprised the loot obtained from the burglarized premises. The court held that the sheriff responsible for the issuance of the warrant had failed to supply sufficient facts to the court to constitute probable cause, and that the later arrest and search suffered from the same defect.
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