Criminal Law
United States v. Alonzo, 991 F.2d 1422 (9th Cir. 1989)
Study notes for United States v. Alonzo: professor notes, cold call prep, exam angles, and memory aids.
Informant testimony can establish probable cause for a warrant if it is corroborated by law enforcement observations.
In the case of United States v. Alonzo, professors often emphasize the importance of the Fourth Amendment's protection against unreasonable searches and seizures, particularly as it pertains to the necessity of establishing probable cause before a warrant can be issued. The Ninth Circuit examined how informant testimony can suffice to establish reasonable cause, especially when it is corroborated by law enforcement's direct observations. This case illustrates the delicate balance between law enforcement's need for effective investigative tools and the protection of individual rights against arbitrary state action.
Additionally, the professors would stress the role of informant reliability and corroboration in the warrant-issuance process. By discussing how the agents' corroboration efforts—including surveillance and the informants' reliability—played a significant role in validating the warrant, students can better understand how the courts navigate the complexities of information gathering in the context of drug trafficking and other criminal enterprises.
A.C.T. - Alonzo's Corroborative Testimony - highlights the requirement for corroboration of informants.
| Case | Distinction |
|---|---|
| Illinois v. Gates | Illinois v. Gates established the totality-of-the-circumstances test, while Alonzo focused on corroboration of informant reliability. |
| Franks v. Delaware | Franks v. Delaware discusses the rights of the accused to challenge the credibility of an affidavit for a warrant; Alonzo focuses on the sufficiency of evidence for warrant issuance. |
Allowing informants' testimonies under certain conditions promotes efficient law enforcement and facilitates the investigation of more serious crimes like drug trafficking.
Relying on informant testimony, especially if uncorroborated, may lead to potential abuses of power and violations of individuals' Fourth Amendment rights.
This case may appear on exams in the context of discussing the Fourth Amendment and warrant requirements, specifically focusing on the role of informant testimony and corroboration in establishing probable cause.