Gates v. Illinois, 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 1453 (1983) (regarding “bare bones search” warrant affidavits).
State v. Roark, 83 N.C.App. 425, 426, 350 S.E.2d 153, 155 (1986) (a “bare bones” affidavit for a search warrant, i.e. “one which says only that the affiant has received reliable information from a credible person and does believe, is not sufficient for a magistrate to find probable cause for a search.”).
State v. Newcomb, 84 N.C.App. 92, 351 S.E.2d 565 (1987) (search warrant affidavit was “devoid of any circumstances that tend to make the informant’s statement credible…. The affidavit contain[ed] a mere naked assertion that the informant at some time saw a ‘room full of marijuana’ growing in defendant’s house.” The Court was also discouraged by the facts that the informant was “not acting against his penal interest[,]” that there was no “indication that he had supplied previous information that proved helpful to the police[,]” and that the officer “made no attempt to corroborate the informant’s story. He did nothing more than verify the defendant lived in the house.”