People v. Titus
The issue in People v. Titus, 880 P.2d 148, 151-52 (Colo 1994) was law enforcement corroboration of an anonymous informant's list of motor vehicle license plates of alleged drug buyers who frequented a suspect's home.
There, the police corroborated that the license plate numbers of the vehicles on the list provided by the anonymous informant matched the description of the vehicles that the informant gave. See id.
But this list was innocuous: "There was nothing in the affidavit to suggest . . . that any of these vehicles belonged to known drug offenders . . . ." Id. at 151.
Thus, the court explained: "The matching of vehicle license plate numbers with vehicle descriptions was not the kind of 'police corroboration' that would serve to establish probable cause in this case.
Absent any additional corroboration--for example, that the owners of the vehicles were involved in illegal activity--it was insufficient to support a finding of probable cause." Id. at 152 .
In Titus the Colorado Supreme Court found that no probable cause existed where the license plate numbers given by an anonymous tipster were innocuous, and the majority distinguishes it on this basis. 880 P.2d at 151-52.
However, the majority fails to mention that in Titus, the police also sent a police informant to the suspect's home to attempt to purchase drugs, at which time the suspect made a number of suspicious statements, the police performed surveillance of the home, and the officer determined the employment status of the suspect (self-employed). All of this was included in the officer's affidavit. Id. at 149-50.