People v. Sloan

This is an interlocutory appeal arising from a denial of the defendant’s motion to suppress blood test results obtained pursuant to a search warrant. The general issue is the establish*163ment of probable cause for search warrants under MCL 780.653; MSA 28.1259(3). The specific issue is one of first impression for Michigan: When a reviewing court assesses whether probable cause has been established for the issuance of a search warrant, may the reviewing court consider sworn, yet unrecorded, oral testimony that, in addition to an affidavit, was presented to the magistrate before he issued the…