Tamburino v. Commonwealth

In Tamburino v. Commonwealth, 218 Va. 821, 825, 241 S.E.2d 762, 765 (1978), an informant approached the police with information about the illegal possession and distribution of drugs. See id. at 822, 241 S.E.2d at 763. A police officer completed an affidavit and obtained a search warrant for Tamburino's residence after witnessing a controlled purchase of drugs by the unidentified informant from "'a subject.'" See 218 Va. at 823, 241 S.E.2d at 763. Applying the more stringent Aguilar-Spinelli test, see 218 Va. at 823-824, 241 S.E.2d at 764, the Supreme Court upheld the affidavit, holding it provided "a sufficient basis for the magistrate's finding of probable cause." Id. at 826, 241 S.E.2d at 765.