Missoula v. Tye
Annotate this CaseAt 1:37 a.m., Haddad reported to Missoula 911 that he was driving on Hillview when a black Acura 2.0 CL with gold badging pulled out in front of him; that the driver was swerving; that he could not describe the driver due to the vehicle’s tinted windows nor see the license plate; and that he would “possibly” be willing to sign a complaint. He provided his name and phone number, but declined to provide his address, indicating he was willing to be contacted by law enforcement. Officers Jones and Horton responded; on Hillview, Horton passed a vehicle that fit Haddad’s description. Jones saw it turn onto 34th Street, searched the area and found a black Acura 2.0 CL in an apartment complex parking lot. Tye was standing near the vehicle. Jones observed that she was swaying, had watery eyes and slow, slurred speech, and smelled of alcohol, and determined Tye was intoxicated. Tye admitted she had several drinks before driving down Hillview. Jones arrested her, then discovered that Haddad lied about his location. Haddad admitted calling 911 from his residence after Tye left that location intoxicated. Haddad did not want Tye to know he was the complainant. The court heard evidence that 911 dispatchers do not regularly use the GPS system, but rely on the information callers provide because it is more accurate, concluded that Jones reasonably relied on Haddad’s information, and denied a motion to suppress. The Montana Supreme Court affirmed, based on the “Pratt” factors: whether the informant identifies himself and exposes himself to criminal and civil liability if the report is false; whether the report is based on the informant’s personal observations; and whether the officer’s own observations corroborated the informant’s information.
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