corroboration requirement in Pennsylvania

2023The corroboration requirement “is based on the principle that because an informant is right about some things, he or she is probably right about other facts also, including the allegation that the object of the tip is engaged -8- J-A24034-22 in criminal activity.” Commonwealth v. Jackson, 698 A.2d 571, 574 (Pa. 1997) (emphasis added; internal citation omitted).

2022See Commonwealth v. Jackson, 698 A.2d 571, 574 (Pa. 1997).

2017The Jackson Court declared that, “a Terry stop may be made on the basis of an anonymous tip, provided the tip is sufficiently corroborated by independent police work to give rise to a reasonable belief that the tip was correct.” Jackson, 698 A.2d at 574 (discussing the holding of Alabama v. White, 496 U.S. 325, 331 (1990)). -7- J-A19008-17 “Essentially, the corroboration requirement is based on the principle that because an informant is right about some things, he or she is probably right about other facts also, including the allegation that the object of the tip is engaged in criminal activit

2017The Jackson Court declared that, “a Terry stop may be made on the basis of an anonymous tip, provided the tip is sufficiently corroborated by independent police work to give rise to a reasonable belief that the tip was correct.” Jackson, 698 A.2d at 574 (discussing the holding of Alabama v. White, 496 U.S. 325, 331 (1990)). -7- J-A19008-17 “Essentially, the corroboration requirement is based on the principle that because an informant is right about some things, he or she is probably right about other facts also, including the allegation that the object of the tip is engaged in criminal activit

1998See U.S. v. Gilbert, 45 F.3d 1163, 1167 (7th Cir.1995) (found it important that the confidential informant predicted the future activities of the defendant); U.S. v. Miller, 925 F.2d 695, 699-700 (4th Cir.1991) (held that corroborating predictive behavior supplied by named informant was important consideration in determining the existence of probable cause to arrest defendant).

1998See U.S. v. Gilbert, 45 F.3d 1163, 1167 (7th Cir.1995) (found it important that the confidential informant predicted the future activities of the defendant); U.S. v. Miller, 925 F.2d 695, 699-700 (4th Cir.1991) (held that corroborating predictive behavior supplied by named informant was important consideration in determining the existence of probable cause to arrest defendant).

1998See U.S. v. Gilbert, 45 F.3d 1163, 1167 (7th Cir.1995) (found it important that the confidential informant predicted the future activities of the defendant); U.S. v. Miller, 925 F.2d 695, 699-700 (4th Cir.1991) (held that corroborating predictive behavior supplied by named informant was important consideration in determining the existence of probable cause to arrest defendant).

1998See U.S. v. Gilbert, 45 F.3d 1163, 1167 (7th Cir.1995) (found it important that the confidential informant predicted the future activities of the defendant); U.S. v. Miller, 925 F.2d 695, 699-700 (4th Cir.1991) (held that corroborating predictive behavior supplied by named informant was important consideration in determining the existence of probable cause to arrest defendant).

1975In the former instance, the corroboration requirement is satisfied “if the independent evidence ‘points to an unlawful killing, although it may indicate as well accident or suicide’ . . . .” Id. at 366 , 329 A.2d at 274 , quoting Commonwealth v. Coontz, 288 Pa. 74, 79 , 135 A. 538, 539 (1927).

1975In the former instance, the corroboration requirement is satisfied “if the independent evidence ‘points to an unlawful killing, although it may indicate as well accident or suicide’ . . . .” Id. at 366 , 329 A.2d at 274 , quoting Commonwealth v. Coontz, 288 Pa. 74, 79 , 135 A. 538, 539 (1927).

1974The public policy underlying the corroboration requirement of the statute is to prevent any “invitation to make reckless accusations by one protected from prosecution by the law itself . . . [which] might well result in serious injustice,” Commonwealth v. Marmon, 210 Pa. Superior Ct. 202, 212 , 232 A.2d 236, 242 (1967), and “to provide a degree of protection against the well-known danger that a participant in the indicted crime may seek to save himself by falsely incriminating a cohort.” Government v. Torres, 476 F.2d 486 , 490 (3d Cir. 1973).

1974The public policy underlying the corroboration requirement of the statute is to prevent any “invitation to make reckless accusations by one protected from prosecution by the law itself . . . [which] might well result in serious injustice,” Commonwealth v. Marmon, 210 Pa. Superior Ct. 202, 212 , 232 A.2d 236, 242 (1967), and “to provide a degree of protection against the well-known danger that a participant in the indicted crime may seek to save himself by falsely incriminating a cohort.” Government v. Torres, 476 F.2d 486 , 490 (3d Cir. 1973).