MT: An improperly certified police officer was still competent as a witness at a suppression hearing under Rule of Evid. 601, 602

An improperly certified police officer was still competent as a witness at a suppression hearing because all witnesses are generally competent to testify to what they saw. Rule of Evid. 601, 602. Under the totality of circumstances, there was probable cause for issuance of the search warrant for defendant’s vehicle. State v. Robertson, 2019 MT 99, 2019 Mont. LEXIS 158 (Apr. 30 2019).

Defendant’s parole search was valid under Samson. United States v. Massengill, 2019 U.S. App. LEXIS 13142 (6th Cir. May 1, 2019).*

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