The following excerpt is from U.S. v. $215,300 U.S. Currency, 882 F.2d 417 (9th Cir. 1989):
2 The government itself has in the past conceded certain of these reports to be "unreliable," see United States v. Portillo, 469 F.2d 907, 908-09 (9th Cir.1972), and we have previously refused to find probable cause despite NADDIS information linking defendant to drug trafficking. See United States v. Prim, 698 F.2d 972, 973-74 & 977 (9th Cir.1983). Some showing of reliability should be offered by the government. Cf. United States v. Spetz, 721 F.2d 1457, 1464 (9th Cir.1983) (government must establish reliability of police dog used in canine search).
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