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this was indispensable, or that an agent cannot have other reasons for believing an informant. An adequate judgment of reliability depends on a number of circumstances. If relatives of an accused give information as in United States v. Naples, 192 F. Supp. 23 (D. D.C.), pending on appeal, C.A. D.C., No. 16436,[1] officers have a right to take the information very seriously, even if they have never received information from such persons before.[2] Very little corroborating information would be needed to justify an officer in reaching the conclusion that the information given was reliable. On the other hand, more corroboration may reasonably be deemed necessary if information came from an anonymous tip or from a source, theretofore unknown, as to which the officers had no
- ↑ Naples, a homicide case, involved information given by the defendant's brother.
- ↑ People v. Witt, 159 Cal. App. 2d 492, cited by petitioners (Pet. Br. 9), while stating, without citing authority, that one Cibrian could not be considered to be a "reliable informant" because he had not theretofore given the police information, reversed this conclusion in the actual holding of the case. Cibrian's statement that a certain car contained "hot stuff" and guns was deemed sufficient to justify the action of the officers in approaching the car with drawn guns, ordering defendant and another man out of the car, and searching the car for weapons. This search disclosed the stolen articles and guns upon which the defendant was later convicted of burglary. The court assumed that the arrest was made only after the findings in the car, but the court obviously thought the information given by Cibrian justified further investigation.
