In County of Jefferson v. Renz, 222 Wis. 2d 424, 426, 588 N.W.2d 267 (Ct. App. 1998) the Court held that a law enforcement officer must have probable cause to arrest an individual for OMVWI before asking him or her to submit to a PBT under Wis. Stat. 343.303. In reversing the decision, the supreme court explained that the legislature intended that probable cause to request a PBT is less than that required to arrest, but more than the "reasonable suspicion" necessary to justify an investigatory stop. See Renz, 231 Wis. 2d at 317. In that case, a Jefferson County sheriff's deputy pulled the defendant over at approximately 2 a.m. for a traffic violation. During an initial conversation, the deputy noticed a strong odor of intoxicants emanating from the defendant's car. He asked the defendant if he had been drinking, and the defendant admitted to consuming "three beers earlier in the evening." The deputy then requested the defendant to perform a series of field sobriety tests to which the defendant consented. Defendant passed the alphabet test, but had some problems with the one-legged stand, the walk-and-turn and the finger-to-nose tests. After these tests, the defendant consented to the deputy's request for a PBT. Upon obtaining a PBT result of .18, the deputy arrested the defendant for OMVWI. On these facts, the supreme court determined that the arresting officer in Renz had the requisite probable cause to request a PBT.