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Warrants – Probable Cause – Expertise of Supporting Officer

State v. James E. Multaler, 2002 WI 35, affirming 2001 WI App 14, 246 Wis. 2d 752, 632 N.W.2d 89For Multaler: Jeffrey W. Jensen


¶43. This court has explained on at least one prior occasion that both the experience and special knowledge of police officers who are applying for search warrants are among the facts that the warrant-issuing court may consider. State v. Harris, 256 Wis. 93, 100, 39 N.W.2d 912 (1949). Similarly, other courts have stated that a government agent’s expert opinion may be considered by the issuing court when making its probable cause determination. See, e.g., United States v. Rabe, 848 F.2d 994, 997 (9th Cir. 1988). Multaler does not dispute these propositions, and he cites no case law holding that in all cases a warrant affiant must possess both field experience pertaining to the type of crime in question and specialized knowledge obtained through other means.

¶48. Investigator Hanrahan’s detailed listing of his sources of information and accompanying credentials, combined with his indication that his opinion was based upon his ‘training and research’ provided a sufficient foundation for the opinion he gave about the behavior patterns of serial killers….


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