Identified but unknown CI did not provide justification for the defendant\u2019s stop because he merely relayed generally known information that shows no reason to believe that a crime was occurring. L.W. v. State, 926 N.E.2d 52 (Ind. App. 2010):<\/p>\n
Here, there is no evidence in the record that law enforcement had verified Shockley’s identity or that his reliability was known prior to the investigatory stop of L.W. On this record, while Shockley identified himself, he was nonetheless a virtual stranger. Neither Officer Cantrell nor the police department knew whether he was “a concerned citizen, a prankster, or an imposter.” See Glass, 769 N.E.2d at 643. And there is no evidence that Shockley identified himself in such a way that would place his credibility at risk or subject himself to criminal penalties. See id. Nor is there any indication that the tipster indicated that he had inside knowledge about the burglary or the suspect. Shockley merely described the suspect’s general build, shirt, and shoes. That same information was available to the general public and did not provide the police with sufficient information to corroborate Shockley’s assertions. See Kellems, 842 N.E.2d at 356. This case is easily distinguishable on its facts from Kellems, where the tipster not only identified herself but was a person known to the police and accurately predicted future behavior.<\/p><\/blockquote>\n
The trial court\u2019s evaluation of the evidence under the totality of circumstances was like the analysis condemned in Arvizu. The totality of circumstances here showed probable cause. State v. Christopher, 2010 Ohio 1816, 2010 Ohio App. LEXIS 1504 (12th Dist. April 26, 2010).*<\/p>\n","protected":false},"excerpt":{"rendered":"
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