What is the test for probable cause in a civil case involving information from a citizen informant?

Higgason v. Superior Court (1985) 170 Cal.App.3d 929, 216 Cal.Rptr. 817, involved similar facts, although unlike the instant case, there was no citizen informant. Police officers had received information from anonymous informants regarding criminal activity. The appellate court found that three anonymous tips corroborated by police observation of innocent activity did [11 Cal.App.4th 1112] not add up to probable cause. (Id., at p. 939, 216 Cal.Rptr. 817.) The court noted that the police investigation had not corroborated any facts in the tips to which any degree of suspicion attached nor any predictions of future activity. (Id., at pp. 938-940, 216 Cal.Rptr. 817.) Instead, the police corroboration merely confirmed that the suspect had the same residence and car mentioned in two of the three tips. (Id., at p. 940, 216 Cal.Rptr. 817.)