California, United States of America
The following excerpt is from People v. Caldera, D058782 (Cal. App. 2012):
As stated, the Harvey-Madden requirement may be satisfied with circumstantial evidence providing a strong inference officers did not manufacture the information. (People v. Orozco, supra, 114 Cal.App.3d at pp. 444-445.) In Orozco, an anonymous call to police about people shooting out of a car was not proved with dispatcher testimony or other evidence, but evidence of spent cartridges found on the ground near the car in question supported "a very strong inference that the police did not make up the information from the informant" and circumstantially proved the veracity of the dispatch to police. (Id. at pp. 444-445.) This evidence negated any sort of " 'do it yourself probable cause. . . .' " (Ibid.)
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