California, United States of America
The following excerpt is from People v. Pressley, 242 Cal.App.2d 555, 51 Cal.Rptr. 563 (Cal. App. 1966):
Although the telephone caller can scarcely be regarded as a 'reliable' informant, her information, taken in its totality, certainly was enough to authorize the officers to go to the address given and to investigate activities there. On arriving at the apartment, the officers observed three persons who fitted the description previously given of the three men allegedly involved. Although that description was hardly enough to justify immediate arrest, the presence, at the [242 Cal.App.2d 559] address given, of three men--no more, nor less--of the respective heights given the officers, again justified the action in pursuing two of them for questioning. That investigatory step disclosed evidence of recent marijuana usage. By this time, we think the officers had enough grounds to arrest the occupant of the apartment. While the caller stood somewhere between the usual 'undercover' addict-information and the citizen householder in People v. Lewis (1966) 240 Cal.App.2d 546, a 46 Cal.Rptr. 579, her information had some reasonable corroboration. By this time the police knew that the three persons named were, in fact, connected with the address given and that one of them had a key to the apartment. At least one of them had recently used marijuana. We cannot say that it was unreasonable to believe that marijuana was, in fact, at that time, in the apartment, under the control of its occupant. It follows that the officers, as they approached the door, had grounds to arrest defendant. This being so, we need not decide whether his act of running away added anything to a probable cause already existent.
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