United States v. Hensley, 469 U.S. 221 (1985).
Reliance On Another Police Department's Wanted Flyer-The Supreme Court held that an investigatory stop made in reliance on another police departments "wanted flyer" was reasonable since the first department's flyer was issued on basis of articulable facts supporting a reasonable suspicion that the defendant had committed an offense. Conversely, the Court stated if the first department did not have probable cause, "an otherwise illegal arrest cannot be insulated from challenge by the decision of the instigating officer to rely on fellow officers to make the arrest."
U.S. v. Wells, 98 F.3d 808 (1996).
In 1996 the Fourth Circuit held that collective knowledge of probable cause is sufficient. In this case, a search was conducted of defendant's apartment pursuant to a warrant that authorized a search for evidence relating to federal bank fraud offenses. A firearm was found, and the supervising agent ordered it seized as evidence since that agent had reviewed the defendant's criminal records prior to the search and knew that the defendant had a prior felony conviction. The court stated that "although the agent who actually seized the weapon pursuant to the supervising agent's instructions had no personal knowledge that [the defendant] was a convicted felon, it is sufficient that the agents collectively had probable cause to believe the weapon was evidence of a crime at the time of the seizure."
State v. Battle, 109 N.C. App. 367 (1993).
In Battle, an officer conducted field sobriety tests after smelling an odor of alcohol on defendant's breath. The officer told the defendant not to drive the vehicle and left. The officer radioed a second officer to keep a lookout for the defendant's vehicle. The second officer saw the vehicle a few minutes later, saw nothing unusual about the operation of the vehicle, and stopped the vehicle, placing defendant under arrest for driving while impaired. The court held that the second officer "did not have the reasonable suspicion necessary to make the stop of defendant's vehicle, based either on his own observations or on any particular information communicated to him" by the first officer.