State v. Hidalgo, 296 Neb. 912

Crime Stoppers anonymous tip (July 10, 2015) reported a Hispanic male "Roberto" (nicknamed "Sporty"), an 18th Street gang member, was a felon in possession of illegal firearms and lived at a specific Omaha address.
Police surveilled the address, observed several tattooed Hispanic men on the porch, and noted a white Nissan Sentra registered to Robert Hidalgo and Jacqueline Linares in the driveway.
Officers’ checks showed utilities in Linares’s name; Hidalgo (born 1987) was identified by gang investigators as an 18th Street gang member with nickname “Shorty.”
A trash pull from the property produced mail for the address and marijuana stems/seeds/leaves.
Based on the tip and investigative corroboration, officers obtained and executed a search warrant for the residence; officers found firearms inside the house, a firearm in a neighboring yard, and a firearm inside the Nissan Sentra. Hidalgo later admitted the gun in the car was his.
Hidalgo (a convicted accessory to a felony) was charged, convicted after a stipulated bench trial of possession of a firearm by a prohibited person, and sentenced to 3–5 years; he appealed, arguing lack of probable cause and improper vehicle search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for search warrant	State: affidavit and corroboration (vehicle registration, utilities, trash pull, officers’ observations) supported probable cause	Hidalgo: anonymous tip unreliable; corroboration only established innocent details; trash marijuana insufficient	Court: Probable cause existed under totality of circumstances; corroboration and trash evidence plus tip supported issuance of warrant; conviction affirmed
Scope of warrant — vehicle search	State: vehicle on premises may be searched as part of warrant scope; affidavit connected vehicle to occupants and referenced vehicles in gang/narcotics context	Hidalgo: warrant described house only; vehicle not listed, so search of Sentra exceeded warrant	Court: Vehicle in driveway contiguous to house fell within warrant scope; affidavit contemplated vehicles; search valid

State v. Hill, 288 Neb. 767 (discussing probable cause and review standard for warrants)
Illinois v. Gates, 462 U.S. 213 (establishing totality-of-the-circumstances test for informant tips)
State v. Vermuele, 234 Neb. 973 (no requirement that alleged crime itself be independently corroborated)
U.S. v. Pennington, 287 F.3d 739 (8th Cir.) (vehicle on premises may fall within the scope of a residence search warrant)