DC: CI’s handler necessary witness at suppression hearing to show PC

At the suppression hearing, the CI’s handler has to testify to what the CI knew so the search does not become merely ratified by the officer’s conclusion that the CI was believable. Here, just the officer conducting the search based on another officer’s relaying of information from the CI was the only witness. Parsons v. United States, 15 A.3d 276 (D.C. App. 2011):

The problem in the present case is that, even applying the collective knowledge doctrine, there was no testimony from which the trial court could have judged the informant’s credibility. Detective Humberson was not the confidential informant’s handler; in fact he had never dealt with the informant prior to the day of Parsons’s arrest. Detective Freeman, who was the handler, presumably could have testified at Parsons’s trial as to the informant’s track record and the existence of other virtuous qualities, but he did not. It appears from the record that the trial court “simply rel[ied] on [Detective Humberson’s] conclusory assertions in deciding whether [his search of Parsons] was justified” and did not, as required by our case law, “evaluate the facts underlying those assertions.” Milline, 856 A.2d at 619; see also Sanders, 751 A.2d at 955 (reversing and remanding because the “tipster’s track record was thinly developed in the trial court”).