State v. Amstutz

Ruled that defendant’s warrantless arrest violated search and seizure clause because, based on information the officer knew at the time of arrest, it was for a completed misdemeanor that occurred outside the officer’s presence, and fact that the officer had information at his disposal in a state-created document that would have given him probable cause to conclude the offense was a felony, or that another officer at dispatch reviewed the document, was not sufficient without the arresting officer’s personal awareness to create such probable cause