Aguilar Spinelli Test Case In Alaska
Informants are divided into two categories under the Aguilar-Spinelli analysis: citizen informants and police informants
See Aguilar v. Texas, 378 U.S. 108, 12 L. Ed. 2d 723, 84 S. Ct. 1509 (1964); Spinelli v. United States, 393 U.S. 410, 21 L. Ed. 2d 637, 89 S. Ct. 584 (1969); State v. Jones, 706 P.2d 317, 324-25 (Alaska 1985).
"For purposes of the Aguilar-Spinelli doctrine, the veracity of a statement given by a police informant whose reliability is unknown may be established by a corroborating statement from another informant.
'Cross-corroboration among informants is a well-accepted method of demonstrating the validity of the information given.'" Lewis v. State, 862 P.2d 181, 186 n.5 (Alaska App. 1993) (quoting State v. Prince, 93 Ore. App. 106, 760 P.2d 1356, 1359-60 (Or. App. 1988) (en banc).
However, in Carter v. State, 910 P.2d 619 (Alaska App. 1996) we noted that cross-corroboration does not enhance credibility when it involves "the mere repetition of a conclusory accusation." Id. at 625
The self-verifying detail test should be used only with respect to the basis of knowledge and not with respect to veracity. ... As explained in Stanley v. State 19 Md. App. 507, 313 A.2d 847 (Md. App. 1974).
the "self-verifying detail" technique cannot repair a defect in the "veracity" prong. the notion that great detail implies personal observation rather than the overhearing of barroom gossip, presupposes an honest informant.
If the informant is concocting a story out of whole cloth, he could fabricate in fine detail as easily as with rough brush strokes. Minute detail tells us nothing about "veracity." Wayne R. LaFave, Search and Seizure 3.3(e), at 156-57 (3d ed. 1996).