State v. Stevens

OPINION

ANDERSON, C.J.

We granted this appeal to determine whether a conclusory allegation in an affidavit that information was provided by a “concerned citizen source” is sufficient to establish the presumptive reliability of the information for the issuance of a search warrant under the Fourth Amendment to the United States Constitution and Article I, § 7 of the Tennessee Constitution. 1

There is a distinction in Tennessee law between “citizen informants” and “criminal informants” or those from the criminal milieu. Information provided by an unnamed ordinary citizen is presumed to be reliable,…