“Citizen informants can provide useful information and play an important role in law enforcement. At the same time, however, it is imperative to recognize the potential for abuse if the information provided by a citizen informant is not reliable.” This statement provides context for the central conflict of City of Missoula v. Tye, in which the Montana Supreme Court held that fabricated information from a 911 caller was sufficiently reliable to establish particularized suspicion for an investigative stop of a suspected impaired driver. The Court applied a three-factor test previously articulated in the 1997 case of State v. Pratt to assess whether the 911 caller’s report containing fabricated information was reliable.
Morgan Chandler, Case Note, City of Missoula v. Tye: Expanding the Scope of the Informant Reliability Analysis, 77 Mont. L. Rev. Online 127, https://scholarship.law.umt.edu/mlr_online/vol77/iss1/17.