State v. Maxwell
In State v. Maxwell, 624 A.2d 926 (Del. 1989), the Delaware Supreme Court held that the trial court committed error when it discounted each of the officers' observations because the officers failed to investigate possible innocent theories for the observations. Id. However, this rule of law does not strip courts of their responsibility to weigh the probative value of evidence presented by looking at all of the facts and circumstances within the Officer's actual knowledge.
The Delaware Supreme Court has held that an officer has probable cause to arrest for a violation of DUI when the officer 'possesses information which would warrant a reasonable man in believing that such a crime has been committed.' Maxwell at 929-930.
It is inappropriate for a trial court to discount the probative value of an officer's probable cause observations because the officer did not eliminate possible innocent explanations for the existence of those observations. Id. at 930.
In determining whether probable cause existed, courts are required to determine whether the totality of the circumstances presented reveal that "based upon their observations, their training, their experience, their investigation, and rational inferences drawn therefrom, the police possessed a quantum of trustworthy factual information, sufficient in themselves to warrant a man of reasonable caution to conclude that probable cause existed to believe" that the defendant committed the offense. Id.