GA: Tipster talking to police on street not just “anonymous tipster”

A woman who flagged down the police to tell them of a potential crime is not an anonymous tipster. The officer saw her and could assess credibility. Therefore, she was considered more reliable. Durden v. State, 320 Ga. App. 218, 739 S.E.2d 676 (2013):

We conclude that there was evidence to support the trial court’s finding that the unidentified woman who flagged down the officer fell into the category of a concerned citizen rather than an anonymous tipster. Generally, as the terminology itself implies, we have distinguished a concerned citizen from an anonymous tipster by the fact that the identity of the citizen is known to the police. See Register, 315 Ga. App. at 778, n. 1 (728 SE2d 292) (2012) (“It is true that when hearsay information is supplied by an identified interested citizen, the citizen’s credibility is not as suspect and the analysis is not as stringent as when information is given by an anonymous tipster”) (citation and punctuation omitted; emphasis in original); Slocum, 267 Ga. App. at 338 (“Where the information is provided to police by an informant who is either an identified interested citizen or an identified victim of a crime, there is a presumption of reliability.”).

Significantly, however, we have held that a citizen who witnesses criminal activity and then immediately reports it in person directly to a police officer also can be deemed a concerned citizen, even if her identity is not known to the police. …

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