We disagree. In Vaughn v. State, 247 Ga. 136, 137 ( 274 S.E.2d 479) (1981), this court stated, in discussing probable cause at the time of arrest that "`[w]hether that arrest was constitutionally valid depends in turn upon whether, at the moment the arrest was made, the officers had probable cause to make it — whether at that moment the facts and circumstances within their knowledge and of which they had reasonably trustworthy information, were sufficient to warrant a prudent man in believing that the petitioner had committed or was committing an offense.'" Citing Beck v. Ohio, 379 U.S. 89 ( 85 S.C. 223, 13 L.Ed.2d 142) (1964).
In Georgia, if probable cause to arrest exists, a warrantless arrest is lawful. Durden v. State, 250 Ga. 325 ( 297 S.E.2d 237) (1982); Vaughn v. State, 247 Ga. 136 ( 274 S.E.2d 479) (1981). The arresting officers testified at trial that they believed that a warrant had been issued in Missouri.
Junior Vaughn and his wife, Helen Vaughn, were indicted for the murder of Ray Gene Oglesby. They were tried separately and each was convicted of murder. We affirmed Helen Vaughn's conviction, Vaughn v. State, 247 Ga. 136 ( 274 S.E.2d 479) (1981), but reversed her husband's because his written confession was admitted in violation of Edwards v. Arizona, 451 U.S. 477 ( 101 S.C. 1880, 68 L.Ed.2d 378) (1981). Vaughn v. State, 248 Ga. 127 ( 281 S.E.2d 594) (1981).
His other enumeration of error need not be considered. We recently affirmed the conviction of Helen Vaughn. Vaughn v. State, 247 Ga. 136 ( 274 S.E.2d 479) (1981). Her case did not involve an in-custody interrogation conducted after an ungranted request was made for the assistance of an attorney.
Probable cause existed if at the time of the arrest the officers had knowledge and reasonably trustworthy information about facts and circumstances sufficient to warrant a prudent man in believing that Borden and Cole had committed an offense. Beck v. Ohio, 379 U.S. 89 ( 85 S.C. 223, 13 L.Ed.2d 142) (1964); Vaughn v. State, 247 Ga. 136 ( 274 S.E.2d 479) (1981); Morgan v. State, 241 Ga. 485, 486 (1) ( 246 S.E.2d 198) (1978); Sanders v. State, 235 Ga. 425, 430 ( 219 S.E.2d 768) (1975); State v. Perry, 234 Ga. 842 ( 218 S.E.2d 559) (1975). Since hearsay information from an informer was relied on, the reasons to support the conclusion that the informer was reliable must be furnished, and it either must be revealed how the informer obtained the information or the informer must describe the criminal activity in such detail that it may be known that the information is more than a casual rumor circulating in the underworld or an accusation based merely on the individual's general reputation.
See Smith v. State, 284 Ga. 304, 307 (3) (a) ( 667 SE2d 65) (2008) (arrest of suspect based on probable cause is reasonable intrusion under Fourth Amendment and justifies search incident to arrest).Vaughn v. State, 247 Ga. 136, 137 ( 274 SE2d 479) (1981). Whether that arrest was constitutionally valid depends in turn upon whether, at the moment the arrest was made, the officers had probable cause to make it — whether at that moment the facts and circumstances within their knowledge and of which they had reasonably trustworthy information were sufficient to warrant a prudent man in believing that the petitioner had committed or was committing an offense.
The facts and circumstances within the knowledge of the officers were sufficient to warrant a prudent man in believing that Clark had committed an offense. Vaughn v. State, 247 Ga. 136 ( 274 S.E.2d 479) (1981); McKenzie v. State, 208 Ga. App. 683, 684 ( 431 S.E.2d 715) (1993). See also OCGA § 17-4-20.
The court determined that a warrantless arrest was justified because under the circumstances, there were facts within their knowledge such as to warrant a prudent man to believe that the wife had committed or was committing an offense. See Vaughn v. State, 247 Ga. 136 ( 274 S.E.2d 479) (1981), applying Beck v. Ohio, 379 U.S. 89 ( 85 SC 223, 13 L.Ed.2d 142) (1964). The officers had probable cause to arrest, and exigent circumstances authorized it without a warrant.
"`Whether [the] arrest was constitutionally valid depends . . . upon whether, at the moment the arrest was made, the officers had probable cause to make it — whether at that moment the facts and circumstances within their knowledge and of which they had reasonably trustworthy information were sufficient to warrant a prudent man in believing that the [appellant] had committed or was committing an offense.' [Cit.]" Vaughn v. State, 247 Ga. 136, 137-138 ( 274 S.E.2d 479) (1981) citing Beck v. Ohio, 379 U.S. 89 ( 85 SC 223, 13 L.Ed.2d 142) (1964). "`Probable cause need not be defined in relation to any one particular element, but may exist because of the totality of circumstances surrounding a transaction.
See, e.g., Mitchell v. State, 173 Ga. App. 560 (1) ( 327 S.E.2d 537) (1985). The Georgia case cited is Vaughn v. State, 247 Ga. 136 ( 274 S.E.2d 479) (1981), but the issue of probable cause to arrest was not reached there. "The trial court's finding on questions of fact and credibility at a suppression hearing must be accepted unless clearly erroneous.