State v. Simms

In State v. Simms, 10 Wn. App. 75, 516 P.2d 1088 (1973), review denied, 83 Wn.2d 1007 (1974), a warrantless search of a parolee's home, based upon an anonymous tip that the informant and defendant were engaged in a drug operation at the defendant's home, was held unconstitutional. The court stated the Fourth Amendment requires that before a parole officer can act upon the tip of an informer, "the information upon which the officer acts must at least carry some indicia of reliability to support an inference that the informant is telling the truth . . . . He must make some attempt to ascertain that he is acting on something more than casual rumor, general reputation, or a mere whim." Simms, 10 Wn. App. at 88.