Valentine v. State, 207 A.3d 566

A confidential informant told Wilmington detectives in early March 2016 that Lamont Valentine kept illegal narcotics and a handgun at 2901 N. Broom St., Apt. 4.
Detectives conducted roughly two weeks of surveillance that mainly confirmed Valentine lived at that address and drove a 2016 Dodge Challenger; they observed one brief duffle-bag exchange.
On March 19 Delaware State Police arrested Valentine in another vehicle and recovered a weapon; on March 30 a building resident made a terroristic-threatening complaint about Valentine.
On March 30 detectives applied for and obtained a warrant to search Valentine’s apartment and car for firearms and residency-related documents; the executed search yielded marijuana, paraphernalia, ammunition in the apartment, and a loaded handgun in the car.
Valentine moved to suppress, arguing the warrant affidavit failed to establish probable cause; the Superior Court denied suppression and Valentine was convicted on several drug-related counts.
The Delaware Supreme Court reversed, holding the affidavit—viewed within its four corners—did not establish probable cause to search for a firearm at the apartment or car.

Issue	Plaintiff's Argument (Valentine)	Defendant's Argument (State)	Held
Was the warrant affidavit sufficient to establish probable cause to search for a firearm and ammunition?	Affidavit relied on an unsigned informant tip that lacked details about basis of knowledge and prior reliability; surveillance and other facts did not meaningfully corroborate the tip.	The tip plus surveillance (address/residence corroboration), Valentine’s March 19 arrest, prior drug conviction, and the March 30 complaint collectively supplied probable cause under the totality of the circumstances.	Reversed. The affidavit failed the four-corners test: the informant’s credibility and basis of knowledge were not sufficiently described, the tip lacked corroborating detail, and the other facts did not meaningfully corroborate the presence of a gun at the locations searched.

Aguilar v. Texas, 378 U.S. 108 (1964) (affidavit must show underlying circumstances for informant reliability)
Spinelli v. United States, 393 U.S. 410 (1969) (informant credibility and basis-of-knowledge requirements)
Illinois v. Gates, 462 U.S. 213 (1983) (adopted totality-of-the-circumstances approach; conclusory informant statements insufficient)
Jones v. State, 28 A.3d 1046 (Del. 2011) (probable cause must exist at time warrant sought)
Holden v. State, 60 A.3d 1110 (Del. 2013) (four-corners review for magistrate’s probable-cause finding)
LeGrande v. State, 947 A.2d 1103 (Del. 2008) (corroboration and informant inquiry in warrant context)