(Citations and punctuation omitted.) State v. Law, 208 Ga. App. 744, 745 ( 432 S.E.2d 110) (1993). We conclude, based on the totality of the circumstances, that the information in the affidavit — as well as that presented to the magistrate orally — provided a sufficient basis for finding probable cause.
Therefore, because the State properly sought and obtained a search warrant before it seized the written materials from Henderson's cell, compare Cohen, McCoy, supra, and the warrant validly authorized the State to seize those materials, we reverse the trial court's grant of Henderson's motion to suppress. See generally State v. Law, 208 Ga. App. 744 ( 432 S.E.2d 110) (1993). Compare Lowe v. State, supra, 203 Ga. App. at 278(1).
See Lance v. State, 275 Ga. 11, 20-21 (19) (b) ( 560 SE2d 663) (2002) (noting that the naming of the witness in an affidavit may offer an additional indicia of reliability); Davis v. State, 214 Ga. App. 36, 37 ( 447 SE2d 68) (1994) (noting that the concerned citizen informer is given a preferred status insofar as testing the credibility of his information). It is undisputed that Bennett was Hall's landlord, which, along with Hall's complaint that his stove needed repairs, provided a reasonable explanation for why Bennett was in Hall's apartment. Although the affidavit does not explicitly state that Bennett believed the substance in the baggies to be contraband, given the description of the material and the fact that Bennett called the police after seeing it, a common sense interpretation of the facts presented in the affidavit is that Bennett believed the material to be contraband. See State v. Law, 208 Ga. App. 744, 745 ( 432 SE2d 110) (1993) (search warrant affidavit was not insufficient even though it failed to show how the informant knew the substance he saw was a narcotic). Thus, the "totality of the circumstances here included evidence that the informant could be considered a concerned citizen and evidence that the informant saw the contraband at the premises occupied by [Hall]."
The reliable informant had no independent knowledge of these facts, but stated that his source "had no reason to lie" to him. Compare State v. Law, 208 Ga. App. 744 ( 432 S.E.2d 110) (1993), in which the informant actually saw the contraband but a third party identified it as such for him. "In determining whether an affidavit sufficiently establishes the probable cause necessary for issuance of a warrant, we employ the totality of the circumstances analysis enunciated in Illinois v. Gates, 462 U.S. 213 (103 SC 2317, 76 L.Ed.2d 527) (1983), and adopted by [the Georgia Supreme Court] in State v. Stephens, 252 Ga. 181 ( 311 S.E.2d 823) (1984), with the admonition that prudence counsels that Gates be considered as the outer limit of probable cause. Under that analysis, the task of the issuing magistrate is simply to make a practical, common-sense decision whether, given all the circumstances set forth in the affidavit before him, including the veracity and basis of knowledge of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place.
]" (Punctuation omitted.) State v. Law, 208 Ga. App. 744, 745 ( 432 S.E.2d 110) (1993). While Clark asserts that the affidavit did not state a factual basis from which the magistrate could determine the reliability of the confidential informant other than the attesting officer's conclusory statement as to the informant's reliability, "the informant in this case demonstrated h[er] reliability by meeting with the [investigator]... and putting [her]self on the line by participating in the controlled purchase."