State v. Simpson, 261 P.3d 90

Defendant Simpson was convicted of DUII and failure to perform duties when property is damaged after a police stop.
Officer Honl received a dispatch report of a traffic accident involving a yellow Corvette, with plate provided, and that the driver was believed intoxicated and that the caller remained at the scene.
Officer Honl stopped a yellow Corvette with the reported plate within a block of the accident scene without observing damage or violations beforehand.
Honl arrested Simpson after observing signs of intoxication at the time of the stop.
Defendant moved to suppress the stop, challenging the existence of reasonable suspicion due to the informant’s reliability.
The trial court denied suppression, finding the report sufficiently reliable; verdicts were entered, and on appeal the conviction was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop based on a citizen informant's report supported by reasonable suspicion?	State argues reliability established by Bybee factors and corroboration.	Simpson argues informant lacked reliability and corroboration was insufficient.	Yes; the report was sufficiently reliable to justify reasonable suspicion.
Do the Bybee/Shumway reliability factors show the informant’s tip was valid for suspicison?	State contends the informant’s detailed tip plus corroboration by the officer supports reliability.	Simpson argues the informant’s anonymity and lack of direct corroboration undermine reliability.	Yes; the tip met sufficient reliability under Bybee/Shumway.
Did the officer’s partial corroboration of the description support the informant’s reliability?	State argues officer encountered the described vehicle consistent with the report, supporting reliability.	Simpson contends lack of full corroboration weakens basis for suspicion.	Yes; observed match to description within proximity supported reliability.

State v. Lindstrom, 37 Or.App. 513, 588 P.2d 44 ((1978)) (anonymous tip can support reasonable suspicion when information has sufficient quantity and quality)
State v. Shumway, 124 Or.App. 131, 861 P.2d 384 ((1993)) (three factors aid reliability assessment of citizen informants)
State v. Bybee, 131 Or.App. 492, 884 P.2d 906 ((1994)) (factors are aid in evaluating reliability, not determinative)
State v. Black, 80 Or.App. 12, 721 P.2d 842 ((1986)) (informant exposure to possible prosecution is a reliability factor)
State v. Mitchele, 240 Or.App. 86, 251 P.3d 760 ((2010)) (reliability considerations for informant tips clarified)
Spinelli v. United States, 393 U.S. 410 ((1969)) (informant reliability governs probable cause standards)