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See, e.g., Ortega, d at 149 n.2 (“[A]lthough ‘probable cause to arrest’ satisfies the search-incident-to-arrest exception to the Fourth Amendment warrant requirement when an arrest is made, ‘probable cause to search’ does not necessarily trigger an exception to the warrant requirement or lead to the conclusion that the search was otherwise reasonable.”); (“[P]robable cause to search and probable cause to arrest are distinct.

E.g., Wiley, d at 269 (first-hand knowledge); –91 (Minn. 1997) (hearsay); Mosley, d at 886, 892 (contemporaneous observations); Munson, d at 132, 136 (predictive information).

We have sometimes referred to this type of limited search as a “pat-down search,” or a “Terry pat-down search,” n.7 (Minn. 1997).

Probable cause to arrest exists when investigating officers “have a reasonable belief that a certain person has committed a crime.”

“[P]olice can base an investigative stop on an informant’ s tip if it has sufficient indicia of reliability.”

“The information necessary to support an investigative stop need not be based on the officer’s personal observations.”

In support of its position, the state relies on

2 “When reviewing the legality of a seizure or search, an appellate court will not reverse the [district] court’s findings unless clearly erroneous or contrary to law.”

Moreover, when considering a challenge to the reliability of informants, we evaluate “police knowledge of both the tipster and the factual circumstances surrounding the tip.” (emphasis added).

When probable cause to arrest is based upon information provided to police by an identified informant, the relevant inquiry is whether the tip has “sufficient indicia of reliability.”

d 687, 691 (Minn. 1997).

An informant’s tip must have “sufficient indicia of reliability.”

Probable cause to arrest exists when police “have a reasonable belief that a certain person has committed a crime.”

Probable cause to arrest exists when the police “have a reasonable belief that a certain person has committed a crime.”

Atwater v. City of Lago Vista, 532 U.S. 318, 354 (2001); -95 (Minn. 1997); see Minn. Stat. § 629.34, subd.

The plain-view exception does not justify a warrantless seizure if the “police lack probable cause to believe that an object in plain view is contra band without conducting some further search of the object.”

“[P]olice can base an investigative stop on an informan t’s tip if it has sufficient indicia of reliability.”

“The test of probable cause to arrest is whethe r the objective facts are such that under the circumstances, a person of ordinary care and prudence would entertain an honest and strong suspicion that a crime has been committed.”

When reviewing the legality of a search, “an appellate court will not reverse the [district] court’s findings unless clearly erroneous or contrary to law.”

“When reviewing the legality of a seizure or search, an appellate court will not reverse the [district] court’s findings unless clearly erroneous or contrary to law.” d 687, 690 (Minn. 1997).

Probable cause to arrest exists when the objective facts are such that “a person of ordinary care and prudence, viewing the totality of the circumstances objectively, would entertain an honest and stro ng suspicion that a specific individual has committed a crime.” State v. Ortega , (emphasis omitted); -95 (Minn. 1997).

The totality of the circumstances includes “the collective knowledge of all investigating officers,” In re Welfare of G. 5 (NMN) M., aff’d, and information supplied by someone other than the arresting officer.

Law enforcement may reasonably rely on information provided by an informant when the information has sufficient “indicia of reliability.” -92 (Minn. 1997).

“The information necessary to support an investigative stop need not be based on the officer ’s personal observations, rather, the police can base an investigative stop on an informant ’s tip if it has sufficient indicia of reliability.”

The reasonable, articulable sus picion standard is satisfied when an officer observes conduct that leads him to reasonably conclude, based on his experience, that “criminal activity may be afoot.” ().

-94 (Minn. 2008); d 687, 691 (Minn. 1997).

“The test of probable cause to arrest is whether the objective facts are such that under the circumstances, a person of ordinary care and prude nce would entertain an honest and strong suspicion that a crime has been committed.”

The reasonable, articulable suspicion standard is met when the officer “observes unusual conduct that leads the officer to reasonably conclude in light of his or her experience that criminal activity may be afoot.” State v. Timberlake , ().

One exception to the warrant requirement permits law enforcement to search “ a person’s body and the area with in his or her immediate control” incident to a “lawful arrest.” Ortega, d at 150; (stating that search incident to arrest may occur before actual arrest so long as there is probable cause for the arrest).