In what circumstances will a court uphold after-the-fact decision that probable cause existed when a tip-off to police was made?

MultiRegion, United States of America

The following excerpt is from U.S. v. Fixen, 780 F.2d 1434 (9th Cir. 1986):

Similarly, this court, in United States v. Woods, 720 F.2d 1022 (9th Cir.1983), affirmed a district court's after-the-fact decision that probable cause existed when the defendant was arrested. In Woods, a previously reliable tipster informed police that a drug transaction was to transpire at the airport:

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