Double anonymous informant hearsay is insufficient to base a search. The state misses the mark by arguing that the defendant doesn’t show that they aren’t reliable since the defendant has no way of knowing who they are in the first place. Sutton v. State, 2013 Ga. App. LEXIS 19 (January 25, 2013). The first anonymous informant’s name was “It”:
While making broad, conclusory statements regarding It's credibility and motivations, however, the affidavit does not say whether It provided the information to the officer over the phone or in person; whether the officer confirmed that It was, in fact, the person he or she claimed to be; whether the officer's conclusions that It was “mature” and employed with no criminal record and no motivation to lie about the defendant was based upon his independent confirmation of those facts or whether he simply relied on It's statements to him; or whether It had previously provided reliable information to the officer or other officers regarding criminal activity by other individuals.
If one anonymous informant almost can never be enough, surely passing one through another can't either.
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