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Arrest — Probable Cause — Citizen-Informant — Connection Between Defendant and Deceased

State v. Joel L. Ritchie, 2000 WI App 136, 237 Wis.2d 664, 614 N.W.2d 837
For Ritchie: Stephen G. Bauer

Holding: Various informants were sufficiently reliable to support probable cause: though they weren’t expressly identified as citizen informants, they wree not suspects but, rather, “were ordinary persons who answered questions and provided information in response to a police investigation of a crime.” ¶15. (Note: though not mentioned by the court, the principle — citizen informants are presumptively reliable as a practical matter — is obvious. See State v. Williams, 225 Wis.2d 159, 176, 591 N.W.2d 823 (1999): “the test of a citizen-informant’s reliability is less strict than the test applicable to the police-informant”). Circumstantial evidence supported probable cause for homicide, including defendant’s relationship with the deceased, her having being found dead in his apartment, and his having been seen with her shortly before she died.


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