The State of Washington, Respondent v. Walter F. Jackson, Petitioners

Summary

The Washington Supreme Court held that Const. art. 1, § 7 requires the Aguilar-Spinelli two-pronged test — establishing both an informant's basis of knowledge and credibility — for informant-based search warrants, expressly declining to follow Illinois v. Gates' totality-of-the-circumstances approach. Applying that test, the court found the credibility prong satisfied by the informant's track record and, although the tip itself lacked basis of knowledge, held that independent police corroboration (surveillance tying Corby's BMW and a marijuana-laden bag to Stern and then to the Jackson address) supplied the missing element, validating the warrant and affirming the convictions. Dimmick, J., concurred in the result without reaching the Gates question, and Utter, J., joined by Williams, C.J., concurred in adopting Aguilar-Spinelli but dissented from its application, contending the corroboration established only innocent facts.