What is the test for passing off information from one officer to another officer that leads to arrest?

California, United States of America


The following excerpt is from People v. Caldera, D058782 (Cal. App. 2012):

[Citation.] '[H]owever, . . . when the first officer passes off information through "official channels" that leads to arrest, the officer must also show basis for his probable cause. In other words, the so-called "Harvey-Madden" rule requires the basis for the first officer's probable cause must be "something other than the imagination of an officer who does not become a witness." [Citation.]' [Citation.] [] Probable cause for a search or an arrest without a warrant may be proven by information passed from one officer to another if it is shown the information was ' " 'factual rather than conclusionary,' related 'specific and articulable facts,' was the product of personal observations by the informing officer, and was reliable." [Citations.]' [Citation.] Ultimately, the issue boils down to whether the latter officer's reliance on the information was reasonable." (People v. Gomez, 117 Cal.App.4th at p. 540.)

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