State v. Pulley

In State v. Pulley, 863 S.W.2d 29 (Tenn. 1993), the Court explained the manner in which the tip of an informant, upon which an investigatory stop is made, must be measured: When a stop is based on the tip of an informant, however, the danger of false reports, through police fabrication or from vindictive or unreliable informants, becomes a concern. Thus, both state and federal courts have developed tests for determining the reliability of informants' tips. In the context of "probable cause" determinations, Tennessee law requires a showing of both the informant's credibility and his or her basis of knowledge. See State v. Jacumin, 778 S.W.2d 430, 436 (Tenn. 1989). The Court in Jacumin held that while independent police corroboration could make up deficiencies in either prong, each prong represents an independently important consideration that 'must be separately considered and satisfied in some way.' (863 S.W.2d at 31.)