DE: Officer’s signing SW affidavit with “Tpr. Santangelo #1826.” showed he was reasonably experienced

Defendant argued that the DUI search warrant lacked probable cause because the officer didn’t specify his training in the affidavit. “The search warrant affidavit is signed ‘Tpr. Santangelo #1826.’ This information allowed the issuing magistrate to reasonably infer that Santangelo was a trained officer with the Delaware State Police and had the requisite training and knowledge to conduct a DUI investigation.” State v. Stout, 2020 Del. C.P. LEXIS 8 (Mar. 19, 2020).

“[O]ne man armed with a firearm was readily visible when the officers arrived. It was also immediately made known to the officers that Appellant was with the man with the firearm and that he had given him the weapon. Based on those facts, we find that the officers’ suspicion that Appellant might also have another weapon on his person to be reasonable. When asked, prior to the commencement of the pat-down search, Appellant admitted to the officers that he did in fact have a firearm on his person.” This was reasonable suspicion. State v. Johnson, 2020-Ohio-1072, 2020 Ohio App. LEXIS 990 (5th Dist. Mar. 19, 2020).*

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