Effenbeck v. State
In Effenbeck v. State, 700 P.2d 811 (Alaska App. 1985), a police dispatcher received a call from an anonymous informant who stated that "a brown Ford, Alaska license number BJL-777, stopped and bought fuel at a Union 76 station, then headed north on the Kenai Spur Highway, and that the driver was intoxicated." The dispatcher relayed this information to a Kenai police officer. This officer eventually located the car in the parking lot of a bar. When the car pulled back onto the highway, the officer immediately stopped it. The traffic stop occurred twenty-two minutes after the dispatcher had relayed the information to the officer.
The Court held that the traffic stop was supported by reasonable suspicion. The Court concluded that it was reasonable to infer from the telephone report that a citizen informant had personally seen Effenbeck at a gas station and had concluded that Effenbeck was intoxicated. The Court noted that the informant accurately described the car, and that the police located the car shortly thereafter. The Court observed that "while a statement that a driver was intoxicated is in part conclusory, it is the kind of shorthand statement of fact that lay witnesses have always been permitted to testify to in court."