Also known as:stool pigeons · stool-pigeon · stoolpigeon · informant · police informant
Written by attorneys · grounded in primary & secondary sources — see below
An informant who supplies law enforcement with information about criminal activity, often in exchange for leniency or payment. The term encompasses both those who report ongoing crimes and those placed undercover to gather evidence or elicit statements.
Sources & Authorities
How it applies
Common Examples
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Waistband Weapon Tip
Sebastian Santos sat in his car outside a coworking space when Officer Lane received a tip from a known security guard that Santos had a pistol in his hoodie pocket. Lane approached, opened the door, and reached directly into the pocket, retrieving the handgun. The guard's information functioned as a stool pigeon tip that supplied the specific location of the weapon.
Totality Tip Evaluation
Sydney Santos reported to police that her neighbor Scott Summers was storing stolen electronics. Officers evaluated the tip under the totality of circumstances, noting Summers's recent cash purchases and evasive behavior. The combination established probable cause even though the stool pigeon's prior reliability was unproven.
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Cases
Model Codes
Dictionaries
Post-Indictment Cell Placement
After indictment, authorities placed Simone Sanders in Sabrina Shah's jail cell. Sanders listened but took no steps to prompt statements. Because the stool pigeon remained passive, the placement did not violate Shah's Sixth Amendment rights.
Paid Informant Elicitation
Stella Shapiro, a paid stool pigeon, was placed in Scott Summers's cell after indictment. Shapiro deliberately asked Summers about the charged offense and recorded his answers. The deliberate elicitation violated Summers's Sixth Amendment right to counsel.
Photo Array Informant
Sebastian Santos identified a suspect from a photo array after a stool pigeon supplied the initial description of the robber. The identification proceeded without the informant appearing at trial.
United States v. Ash413 U.S. 300 (1973)
Reporter Source Protection
A journalist refused to name the stool pigeon who provided details of a hashish operation. The court rejected a First Amendment claim and ordered disclosure to the grand jury.
Branzburg v. Hayes408 U.S. 665 (1972)
Common questions
Frequently Asked
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Does a stool pigeon's tip alone establish probable cause?+
No. An informant's tip is evaluated under the totality of the circumstances. Veracity, reliability, and basis of knowledge are relevant but not rigid prerequisites. A strong showing on one factor can compensate for weakness on others.
When does placement of a stool pigeon in a defendant's cell violate the Sixth Amendment?+
Placement after indictment violates the right to counsel only when the informant deliberately elicits incriminating statements about the charged offense. Mere listening does not trigger a violation.
Can an undercover stool pigeon create a conspiracy under the bilateral approach?+
No. At common law a conspiracy requires at least two persons who genuinely share the criminal objective. When one participant is a stool pigeon who only feigns agreement to gather evidence, no true meeting of the minds occurs and neither party can be convicted.
May an officer reach directly into clothing based on a stool pigeon's tip?+
Yes. When an officer conducting a Terry-type stop has specific information from an informant that a weapon is hidden in a precise location, the officer may reach directly into that area without first conducting a full pat-down.
541 U.S. 36 (2004)Evidence
…v. United States , 483 U. S. 171, 181-184 (1987), admitted statements made unwittingly to a Federal Bureau of Investigation informant after applying a more general test that did not make prior cross-examination an indispensable requirement.[^maj-8] Lee v. Illinois , 476 U. S. 530 (1986), on which the State relies, is…
Criminal Law Constitutional ProtectionsConstitutional protections of accused persons · Arrest, search, and seizure [Fourth Amendment]NEXTGENFoundational