Arrest – Probable Cause 

Posted: 1:00 am Mon, August 17, 2009
By Minnesota Lawyer

Where two officers observed what they believed to be a drug transaction between a man and a woman in a retail parking lot; the woman returned to a van in which defendant was a passenger; the man admitted that he had just purchased crack cocaine from the woman, that he had previously bought drugs from her, and that defendant had accompanied the woman during prior drug transactions; and when an officer approached the van, he saw defendant holding $160 in cash and found no cash on the woman; we conclude that the officer had probable cause to arrest defendant.

We also conclude that the District Court did not abuse its discretion by admitting <I>Spreigl<P> evidence of defendant’s prior controlled-substance conviction.

Affirmed.