who has never before reported a crime to the police may, in fact, be more reliable than one who supplies information on a regular basis. “The latter is likely to be someone who is himself involved in criminal activity or is, at least, someone who enjoys the confidence of criminals.” Wayne R. LaFave, Search and Seizure § 3.3 (3d ed.1996). This case is governed by Illinois v. Gates, 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983), which instructs that the totality of the circumstances determines whether reliance on the tip was reasonable. Key considerations include Ms. Steele’s “veracity” and “reliability.” These factors were presumed since she was a citizen-informant reporting criminal activity in the scope of her employment. See Edwards v. Cabrera, 58 F.3d 290, 294 (7th Cir.1995)(<HOLDING>). Accordingly, the lower court erred in relying
holding design planning and enforcement of bus safety rules for school bus transportation were not operation of motor vehicle under section 4145 holding corroboration is not a necessity where confidential informants reliability was well established and his tip was based on direct personal observation of criminal activity holding that the defendants prior conviction referenced in his presentence report could be taken as admitted because he had made no objection to the facts in his report holding that an anonymous tip must have sufficient indicia of reliability to justify a stop and frisk holding that a tip from a bus driver made via the bus dispatcher was entitled to a bolstered inference of reliability since he would be risking his employers displeasure by making a false report