Sammy Page v. State, 10-15-00120-CR

Sammy Page pleaded guilty to: possession of a Penalty Group 3 controlled substance (<28 g) (drug‑free zone); possession with intent to deliver a Penalty Group 1 controlled substance (1–4 g) (drug‑free zone); and unlawful possession of a firearm by a felon. Sentences: 20 months (state jail), 36 years, and 10 years, with the 10‑year term consecutive to the others.
Before pleading, Page moved to suppress evidence obtained via a search warrant, arguing the warrant affidavit lacked probable cause because it relied on unverified, anonymous informants.
The affidavit recited a CI who observed “Sammy” possessing methamphetamine within 48 hours and who had provided reliable information to the affiant on at least three prior occasions; a separate CS identified Page as the resident and described his car and alleged drug sales.
The affidavit also recited Page’s criminal history and the affiant’s request for a no‑knock warrant due to alleged firearm possession; the magistrate found probable cause and issued the warrant, which yielded drugs and a pistol.
At the suppression hearing, the only evidence was the affidavit, the warrant, and the inventory; the trial court denied suppression. Page appealed, arguing the affidavit failed to establish informant reliability and thus probable cause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether affidavit supplied probable cause for a search warrant	Page: affidavit relied on unverified anonymous informants; CI/CS reliability not sufficiently shown; affiant made conclusory reliability assertions; no independent corroboration	State: affidavit showed CI observed drugs within 48 hours and had provided reliable tips on prior occasions; magistrate may draw reasonable inferences; totality of circumstances supports probable cause	Court: affidavit adequate under totality of circumstances; CI’s prior reliable tips and recent firsthand observation supplied a substantial basis for probable cause; suppression denial affirmed

Illinois v. Gates, 462 U.S. 213 (established totality‑of‑circumstances test for informant tips and magistrate deference)
State v. McLain, 337 S.W.3d 268 (discusses four‑corners review and deferential standard for warrant affidavits)
State v. Duarte, 389 S.W.3d 349 (an anonymous/first‑time tip may be insufficient absent corroboration; distinguishes cases where informant has a track record)
Hegdal v. State, 488 S.W.2d 782 (affidavit based solely on a CI who personally observed contraband within 48 hours can suffice when CI shown reliable)
United States v. Ventresca, 380 U.S. 102 (affidavit need not contain direct observations by affiant; magistrate may be informed of underlying circumstances supporting informant credibility)
State v. Ozuna, 88 S.W.3d 307 (informant veracity, reliability, and basis of knowledge are intertwined factors in assessing probable cause)