State v. Hidalgo, 296 Neb. 912

Omaha police received an anonymous Crime Stoppers tip that a Hispanic male called "Roberto" (nickname “Sporty”), an 18th Street gang member aged about 30–35, lived at a given Omaha address and possessed illegal firearms.
Officers surveilled the address, observed Hispanic males on the porch, checked a white Nissan Sentra registered to Robert Hidalgo and Jacqueline Linares, and found utilities/mail linking the residence to Linares.
Officers’ gang unit records identified Robert (born May 1987) as an 18th Street gang member with the nickname “Shorty.”
A trash pull from the residence produced mail addressed to the location and marijuana stems/seeds/leaves.
Based on the tip plus investigative corroboration, officers obtained and executed a warrant for the residence; they found firearms in the house, a firearm in an adjacent yard, and a firearm in the Nissan Sentra parked in the driveway. Hidalgo later admitted the gun in the car was his.
Hidalgo (a prior felony accessory conviction) was convicted after a stipulated bench trial for possession of a firearm by a prohibited person and appealed, arguing lack of probable cause for the warrant and that the vehicle search exceeded the warrant’s scope.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether affidavit supported probable cause for search warrant	Tip was anonymous and unreliable; corroboration only confirmed innocent details; trash marijuana insufficient to make contraband likely	Police investigation corroborated key tip items (name, residence, gang affiliation, presence of Hispanics of relevant age, vehicle registration, mail, trash marijuana); totality supports probable cause	Warrant supported by probable cause under totality of circumstances; suppression denied
Whether vehicle parked at the property could be searched under the warrant	Warrant described only the house and did not list the vehicle, so search of Sentra violated Fourth Amendment	Vehicle was in driveway contiguous to the described premises; affidavit and no-knock language anticipated weapons in vehicles used in narcotics/gang activity; vehicle search fell within scope	Search of vehicle valid under the warrant; vehicle search upheld

State v. Hill, 288 Neb. 767, 851 N.W.2d 670 (2014) (sets Nebraska standards for probable cause review and four-corners rule)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for informant tips)
State v. Vermuele, 234 Neb. 973, 453 N.W.2d 441 (1990) (no requirement that the crime itself be fully corroborated to justify probable cause)
U.S. v. Pennington, 287 F.3d 739 (8th Cir. 2002) (vehicles on premises described in a warrant may fall within the warrant’s scope when affidavit shows connection)