States v. Ingrao, 897 F.2d 860, 862 (7th Cir. 1990); United States v. Carrillo, 902 F.2d 1405, 1412 (9th Cir. 1990). Defendant concedes that the officers had reasonable suspicion to detain him temporarily to inquire into his activity, but maintains that the evidence did not establish probable cause for arrest. Probable cause for a warrantless arrest requires the same evidence required for issuance of a warrant under VR.Cr.E 4(b). VR.Cr.E 3(a). Rule 4(b) provides that a judicial officer may issue a warrant upon finding “that there is probable cause to believe that an offense has been committed and that the defendant has committed it.” A finding of probable cause must be based on substantial evidence. VR.Cr.E 4(b); see also State v. Towne, 158 Vt. 607, 615, 615 A.2d 484, 489 (1992) (<HOLDING>). Thus, law enforcement officers may arrest a
holding that a totality of circumstances standard was proper for determining probable cause for issuance of a search warrant based on information from an informant holding that court must examine totality of circumstances to determine whether substantial evidence supports issuance of search warrant holding warrant valid where search warrant application affidavit was signed and probable cause existed for issuance of warrant holding threat to obtain a search warrant if individual does not consent to a search is just one factor in deciding whether the totality of the circumstances supports a voluntary consent finding holding that the reasonableness inquiry is based upon the totality of the circumstances in determining whether or not a search was reasonable