holding that Washington uses the Augilar-Spinelli test to evaluate informants' tips
How later courts described this case
- holding that Washington uses the Augilar-Spinelli test to evaluate informants' tips
- noting that if a tip standing alone or partially corroborated, falls short of probable cause, it still has a place in law enforcement by prompting a police investigation or further investigatory work that establishes the requisite probable cause
- suggesting that analysis under the "totality of the circumstances" approach of Illinois v. Gates, 462 U.S. 213, 76 L. Ed. 2d 527, 103 S. Ct. 2317 (1983), is unnecessary if "the stricter requirements of the Aguilar-Spinelli test" are satisfied
- finding that the Gates totality-of the-circumstances approach lacks sufficient specificity and analytical structure to pass the state constitutional muster
Written by the judges who cited it.
Distinguished
Distinguished by State v. Lee, 199 P.3d 445 (2008)
¶ 19 Nonetheless, the Jackson decision is inapposite to the issue presented here: the appropriate test under article I, section 7 for an investigatory stop based partly or wholly on an informant's tip.
The opinion
Dimmick, J.
(concurring in the result) — I concur in the result but disagree with the majority's conclusion that this is a proper case in which to decide the propriety of following Illinois v. Gates, _U.S._, 76 L. Ed. 2d 527 , 103 S. Ct. 2317 (1983). Since the majority holds that the warrant satisfied the stricter requirements of the Aguilar-Spinelli test, it is unnecessary to decide whether this court should follow Gates.