What is the test for corroboration of information provided by an informant in a criminal case?

California, United States of America


The following excerpt is from People v. Hernandez, A135426, A138001 (Cal. App. 2014):

In such a case, there is no requirement for strict corroboration of the information; the court need only conduct a "practical, nontechnical" review of the circumstances. (People v. Hansborough (1988) 199 Cal.App.3d 579, 584.)

Veracity also may be demonstrated through independent police corroboration of the information provided. (People v. Terrones (1989) 212 Cal.App.3d 139, 146-147.) People v. Rochen (1988) 203 Cal.App.3d 684, 687-688.) For example, in People v. Rochen, supra, 203 Cal.App.3d 684, a police officer's affidavit stated he had learned from an informant that a woman named Nellie sold drugs from her home. The informant gave the officer Nellie's telephone number, and when the officer dialed the number a female answered and identified herself as Nellie. The female agreed to sell drugs to the informant. The court held this was sufficient corroboration of the informant's statements, even though there was no verification that Nellie lived at the address in question. It stated: "The purpose served by corroboration is 'to establish that the information provided by the informant did not constitute a made-up story, one fabricated out of whole cloth. Corroboration of part of the information provided by the informant [gives] credibility to the remainder of the information.' [Citation.]" (People v. Rochen, supra, 203 Cal.App.3d at p. 689.)

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