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Courts “apply an objective standard for determining the lawfulness of an arrest or a search by taking into account the totality of the circumstances to determine whether the police have probable cause to believe that a crime has been committed.” -80 (Minn. App. 2001).

in which this court concluded that police officers had probable cause to arrest a person who was engaging in conduct that, based on the officers’ training and experience, was consistent with selling drugs.

(“The fact that there might have been an innocent explanation for [the defendant’s] conduct does not demonstrate that the officers could not reasonably believe that [the defendant] had committed a crime.”).

But “[t]he fact that there might have been an innocent explanation for [the defendant’s] conduct does not demonstrate that the officers could not reasonably believe that [the defendant] had committed a crime.”

This court’s , is instructive on this point.

“To establish probable cause, facts need not exclude all innocent explanations for conduct nor conclusively show that conduct was illegal.”

the officer is entitled to assess probable cause in light of his 13 experience.” (quotations omitted), rev. denied (Minn. June 21, 1989); (citing Anderson).

“To establish probable cause, facts need not exclude all innocent explanations for conduct nor conclusively show that conduct was illegal.”

“To establish probable cause, facts need not exclude all innocent explanations for conduct nor conclusively show that conduct was illegal.” State v. Hawkins

“To establish probable cause, facts need not exclude all innocent explanations for conduct nor conclusively show that conduct was illegal.” d 576, 577 (Minn. App. 2001).

-41 (Minn. App. 1984); (explaining that mere possibility of an innocent explanation for conduct does not negate probable cause).

See State v. Hawkins , d 576, 580 (Minn. App. 2001) (noting “[t]he fact that there might have been an innocent explanation for [defendant’s] conduct does not demonstrate that the officers could not reasonably believe that [defendant] had committed a crime”).

State v. Hawkins , (stating that possibility of innocent explanation does not defeat probable cause).

In State v. Hawkins , officers observed the defendant riding a bicycle around an intersection for about 15 minutes, during which the defendant “whistled and waved at approa ching vehicles, ” which officers described as “a common way for street-level narcotics dealers to get people’s attention and let them know that they are selling narcotics.”

First, it must be noted that “[t]he fact that there might have been an inno cent explanation for [appellant’ s] conduct does not demonstrate that the officers could not reasonably believe that [he] had committed a crime.”

“The fact that there might have been an innocent explan ation for [a defendant’s] conduct does not demonstrate that [an officer] could not re asonably believe that [the defendant] had committed a crime.”

In determining whether probable cause exists, this court “takes into account the totality of the circumstances, including the expertise and experience of the arresting police officers.” State v. Hawkins , d 576, 580 (Minn. App. 2001).

d 576, 580 (Minn. App. 2001).

“The lawfulness of an arrest is determined by an objective standard that takes into account the totality of the circumstances, including the expertise and experience of the arresting police officers.”

(quoting United States v. Sanchez, 689 F.2d 508, 515-16 (5th Cir.1982)).

“innocence” which is reasonably consistent with the circumstances shown.’ ” (Minn.App.