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Cox further argues that, even if explicit vouching did not occur, the testimony impliedly vouched for victim’s testimony, rev. denied (Minn. June 16, 2020) d 573 (Minn. App. 1994).

This court has also stated that referring to a defendant as a drug dealer constitutes prosecutorial misconduct where “[t]he prosecutor was improperly attempting to prove appellant’s guilt by establishing his character as a drug dealer.” (citing Minn. R. Evid.

The state argues that Moore waived appellate review of these issues, because he failed to object as a matter of “defensive strategy.” But our precedent provides that, “even in the absence of objection by counsel,” appellate courts may take note of “plain errors affecting substantial rights.” Minn. R. Crim.

Appellant cites one case, to support his assertion that “[i]t is improper for a prosecutor to imply he or she has personal knowledge [about] whether a witness is telling the truth.” In Richardson, a case pervaded with misconduct, the prosecutor asked a lawyer-witness at trial if he was aware that lawyers cannot ethicall

(analyzing objected-to and unobjected-to errors together because the collective effect of the errors “constitute[d] plain error”).

“Although police officers may rely on training and experience to draw inferences and make deductions, mere suspicion does not equal probable cause.”

nduct where prosecutor asked whether defendant knew last name of potential witness and questioned whether that witness could have helped with defendant’s alibi); State v. Redd, 310 Minn. 145, 146, d 257, 258 (1976) (finding misco nduct where prosecutor argued in closing that defendant failed to call fingerprint expert to challenge state’s fingerprint expert); (finding misconduct where prosecut or questioned defendant about his failure to call potentially helpful witnesses); (finding misconduct w

Griller, d at 741 ; see also State v. Richardson (holding that incidents (several) of prosecutorial misconduct constituted plain error because evidence of appellant’s guilt, though considerable, was not overwhelming).

ABA Standards for Criminal Justice Prosecution Function and Defense Function, standards 3-5.8, 3-5.9 (Third Ed. 1993)

(“Although police officers may rely *777 on training and experience to draw inferences and make deductions, mere suspicion does not equal probable cause.” ()).

580 (Minn.App.1994) (warrant supported by probable cause where police saw informant meet with suspected middleman, but not with appellant).

The probable cause requirement is satisfied “if the affidavit sets forth competent evidence sufficient to lead a reasonably prudent person to believe there is a basis for the search.”

(noting prosecutor’s question to witness’s attorney improperly implied prosecutor had personal knowledge state’s witness testified truthfully).

American Bar Association Standards for Criminal Justice, Standard 3-5.6(b) (2d ed. 1980)

V (no person shall be compelled in any criminal case to be a witness against himself); (a defendant may not be impeached by his failure to offer alibi evidence at any time prior to trial).