State v. Eason

In State v. Eason, 328 N.C. 409, 402 S.E.2d 809 (1991), the defendant argued that the statements of the informant in the search warrant affidavit did not possess "sufficient aspects of reliability and credibility to establish probable cause." Id. at 419, 402 S.E.2d at 813. Applying the totality of the circumstances test, our Supreme Court recognized that "the informant who provided the information for the search warrant was Doris T. Hoffman, a 'citizen-informant' whose name appeared in the search warrant affidavit." Id. at 419-20, 402 S.E.2d at 814. Our Supreme Court concluded that the fact that the citizen-informant was named and identified "provided the magistrate with enough information to permit him to determine that Doris T. Hoffman was reliable." Id. at 420, 402 S.E.2d at 814. Moreover, the affidavit stated that Doris T. Hoffman was the defendant's mother and that she gave detailed information that implicated the defendant in the crimes at issue. Id. O ur Supreme Court held that "there was more than a 'substantial basis' for the magistrate's determination that probable cause existed." Id.