Elrod, Gordon Heath, 538 S.W.3d 551

On April 27–28, 2015 Mesquite police arrested Marsha Stovall after she attempted to cash a suspicious payroll check; officers seized IDs, credit cards, a notebook with names/SSNs, and a counterfeit check from her person.
Investigator Smith interviewed Stovall in jail; she gave a detailed statement that Room 119 at the Executive Inn (occupied by Gordon Elrod and Alicia/Alisha Davis) was the site where counterfeit checks, fake IDs, and social-security cards were printed using multiple computers and printers, and that the defendants used stolen mail for the operation.
Officers had earlier that evening (April 27) visited Room 119 and observed computers and printers; they later obtained a search warrant for Room 119 on April 28 and executed it, seizing large quantities of identifying information and equipment.
Elrod moved to suppress the evidence, arguing the affidavit lacked probable cause and failed to establish the informant’s reliability; the trial court granted the motion and the Fifth Court of Appeals affirmed.
The State sought discretionary review; the Court of Criminal Appeals reversed, holding the affidavit contained sufficient particularized facts from a named, first‑hand informant (and independent corroboration) to support probable cause.

Issue	State's Argument	Elrod's Argument	Held
Whether affidavit established probable cause to search Room 119	Affidavit contained detailed, first‑hand statements from a named informant, against her penal interest, plus officer corroboration (computers/printers observed)	Tip lacked independent corroboration; informant unreliable; four‑corners of affidavit insufficient	Probable cause existed; warrant valid
Whether named informant’s tip required further proof of reliability	Named, eyewitness informant who was involved in the crime provided detailed, penal‑interest statements, which are sufficiently reliable	Informant’s criminal milieu undermines reliability; cannot stand alone	Named informant’s detailed admission and corroboration made her reasonably trustworthy
Relevance of officers’ prior visit to Room 119 (April 27)	Visit provided independent corroboration (observed computers/printers) supporting informant’s account	Visit was unexplained and thus discounted by trial court/court of appeals	Magistrate could reasonably infer the visit corroborated the informant’s claims
Application of Duarte precedent (informant reliability/probable cause)	Duarte is distinguishable: that case involved an unnamed informant and boilerplate affidavit; here facts were particularized	Duarte controls to negate probable cause where informant reliability is uncertain	Duarte distinguished; affidavit here had materially greater detail and corroboration

Illinois v. Gates, 462 U.S. 213 (1983) (probable cause is based on a totality‑of‑the‑circumstances and common‑sense inferences)
State v. Duarte, 389 S.W.3d 349 (Tex. Crim. App. 2012) (anonymity/boilerplate tips insufficient; magistrate needs substantial basis to find probable cause)
Matamoros v. State, 901 S.W.2d 470 (Tex. Crim. App. 1995) (named informant’s statement showing direct knowledge can justify a warrant)
Wilkerson v. State, 726 S.W.2d 542 (Tex. Crim. App. 1986) (information suggesting personal and direct knowledge by informant is entitled to credibility)
Rodriguez v. State, 232 S.W.3d 55 (Tex. Crim. App. 2007) (deferential review of magistrate’s probable‑cause determination)