State v. Anastasia A. Lusty, 2010AP2827-CR, District 2, 9/21/11
Independent police investigation sufficiently corroborated enough details of tips from anonymous informants to support probable cause for a search warrant.
¶9 We reject Lusty’s argument. Based on our reading of the record, we are more than satisfied that the facts before the magistrate, viewed in totality, supported the issuance of the search warrant. First, independent police work corroborated details given by the tipsters, see id.: police independently confirmed that Lusty lived at the address given by the tipsters and that there was short-term traffic at Lusty’s residence; second, police found—in garbage left on the curb directly outside of Lusty’s residence—drugs and evidence of dealing along with mail addressed to Lusty; third, police determined that Lusty had a drug-related arrest. Therefore, there is a direct connection between the tips and the evidence corroborating the tips, which evidence in turn connected Lusty to the sale of drugs.
Test for reviewing search warrant recited, ¶7.