What is the evidentiary burden of evidence against a police field officer in a civil case?

" '[I]f the detaining officer himself [or herself] does not have personal knowledge of facts justifying the detention, but acts solely on the basis of information or direction given him through police channels, the prosecution must establish in court, when challenged, evidence showing that the officer who originally furnished the information ... was in possession of facts amounting to circumstances short of probable cause which would have justified him to personally make the detention.' [Citation.]" (People v. Orozco (1981) 114 Cal.App.3d 435, 444.)

In such situations, the prosecution can meet its evidentiary burden by introducing direct evidence about the source for the information, such as calling the police dispatcher at the suppression hearing to testify about the information conveyed to the field officer. (People v. Brown, supra, 61 Cal.4th at p. 983.) It may also be satisfied by "proof of

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transmission to one police department of official information from a different police agency ...." (People v. Armstrong (1991) 232 Cal.App.3d 228, 246.)