Any other rule would lead to the totally unacceptable result that public-spirited citizens interested only in law enforcement could seldom furnish information sufficient to establish probable cause. Among the cases which hold this view are State v. Perry (Mo. 1973), 499 S.W.2d 473, 475 (citizen-informant may reasonably be deemed to be reliable); State v. Lindquist (1973), 295 Minn. 398, 205 N.W.2d 333, 335 (first-time private citizen informer not involved in criminal event he reports should be presumed to be telling the truth); State v. Paszek, 50 Wis.2d 619, 184 N.W.2d 836, 843 (1971) (element of prior reliability should not be adhered to in case of private citizen informant); People v. Zimnicki, 29 Cal.App.3d 577, 105 Cal.Rptr. 614, 615-617 (1972) (citizen-informer rule requires some measure of either credibility or corroboration but not to same extent as in case of other informant); cf. State v. Lynch, supra, 197 N.W.2d at 192 (statements made to airline stewardess). Although not directly in point, the discussion in United States v. Unger (7th Cir. 1972), 469 F.2d 1283, 1286, 1287 and McCreary v. Sigler (8th Cir. 1969), 406 F.2d 1264, 1268, 1269 further supports such a conclusion.
Nevertheless, it is still necessary to show that the officers had some additional knowledge to support a belief that the car contained contraband. State v. McClung, 66 Wn.2d 654, 404 P.2d 460 (1965); State v. Bantam, 163 Wn. 598, 1 P.2d 861 (1931); Whiteley v. Warden, Wyoming State Penitentiary, 401 U.S. 560, 28 L.Ed.2d 306, 91 S.Ct. 1031 (1971); United States v. Wilson, 465 F.2d 1290 (7th Cir. 1972); People v. Zimnicki, 29 Cal.App.3d 577, 105 Cal.Rptr. 614 (1972); J. Cook, Constitutional Rights of the Accused: Pretrial Rights § 37 (1972). In the instant case, the only information the officers had after they commenced the inventory search concerning the presence of cocaine was the police radio broadcast of an anonymous tip that there were narcotics in the key case of defendant's car.
He would be expected to be motivated by factors which are consistent with law enforcement goals. Consequently, an individual of this kind may be regarded as trustworthy and information imparted by him to a policeman concerning a criminal event would not especially entail further exploration or verification of his personal credibility or reliability before appropriate police action is undertaken. Erickson v. State, 507 P.2d 508 (Alaska Sup.Ct. 1973); People v. Zimnicki, 29 Cal.App.3d 577, 105 Cal.Rptr. 614 (D. Ct. App. 1972); Gaskins v. United States, 262 A.2d 810 (D.C.Ct.App. 1970); People v. Davis, 10 Ill.App.3d 611, 295 N.E.2d 108 (App. Ct. 1973); People v. Wayne, 9 Ill.App.3d 344, 292 N.E.2d 186 (App.Ct. 1972); People v. Arthurs, 24 N.Y.2d 688, 301 N.Y.S.2d 614, 249 N.E.2d 462 (Ct.App. 1969).