State of Utah v. Deluna

In State of Utah v. Deluna, 2001 UT App 401, 40 P.3d 1136 (Utah App. 2001), a concerned family member, referred to in the affidavit as "CFM," had been in the defendant's apartment where CFM's niece, the niece's 4-year-old daughter, and the defendant lived. CFM provided information to police officers that the defendant had been operating a methamphetamine laboratory there. The court in State v. Deluna, supra, found that CFM was a citizen informant, noting that reliability and voracity are generally assumed when the informant is a citizen who receives nothing from the police in exchange for the information.