California, United States of America
The following excerpt is from People v. Caldera, D058782 (Cal. App. 2012):
[Citation.] '[H]owever, . . . when the first officer passes off information through "official channels" that leads to arrest, the officer must also show basis for his probable cause. In other words, the so-called "Harvey-Madden" rule requires the basis for the first officer's probable cause must be "something other than the imagination of an officer who does not become a witness." [Citation.]' [Citation.] [] Probable cause for a search or an arrest without a warrant may be proven by information passed from one officer to another if it is shown the information was ' " 'factual rather than conclusionary,' related 'specific and articulable facts,' was the product of personal observations by the informing officer, and was reliable." [Citations.]' [Citation.] Ultimately, the issue boils down to whether the latter officer's reliance on the information was reasonable." (People v. Gomez, 117 Cal.App.4th at p. 540.)
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