People of Michigan v. Adam Christopher Robe, 358655

Defendant (Robe) was in a T‑bone collision; evidence showed the other driver ran a red light and an eyewitness and crash-data review indicated Robe was not at fault.
Officer Norris administered a preliminary-breath test (PBT) after ~3 minutes of observation (administrative rule requires 15 minutes); the PBT indicated .114 BAC.
Based in part on the PBT result, Norris obtained a warrant for a blood draw; hospital blood tests later showed .134 BAC.
On initial suppression proceedings the trial court denied suppression of the PBT; this Court reversed because the officer failed to observe Robe for the required 15 minutes and directed the trial court to determine probable cause without the PBT.
On remand the trial court found the warrant was supported by probable cause independent of the PBT and denied suppression of the blood evidence; the Court of Appeals now reverses that finding, vacates the denial, and remands for further proceedings on good‑faith issues.

Issue	People’s Argument	Robe’s Argument	Held
Whether the affidavit—excluding the suppressed PBT and its resulting admission—established probable cause for a blood-warrant	Affidavit showed a crash, officer observations, and the PBT (argued usable or still probative)	Without PBT or related admission, affidavit contains only a crash claim and lack of SFSTs—insufficient to infer intoxication	Reversed: affidavit without the PBT failed to provide probable cause for the warrant
Whether the good‑faith exception salvages the blood evidence despite an invalid warrant	Warrant issued by magistrate supports officers’ objective good faith reliance	Officer may have omitted or failed to disclose material facts (fault evidence, PBT defects); good faith is questionable	Remanded: trial court must determine in the first instance whether any good‑faith exception applies

People v Kazmierczak, 461 Mich 411 (probable‑cause standard for search warrants)
People v Nunez, 242 Mich App 610 (warrant requires oath or affirmation)
People v Martin, 271 Mich App 280 (affidavit must contain facts within affiant’s knowledge, not conclusions)
People v Echavarria, 233 Mich App 356 (commonsense, totality‑of‑circumstances review of affidavits)
People v Dillon, 296 Mich App 506 (clear‑error standard for suppression factfindings)
People v Williams, 472 Mich 308 (de novo review of suppression rulings applying constitutional standards)
People v Hellstrom, 264 Mich App 187 (exclusionary rule and introduction to good‑faith exception)
People v Czuprynski, 325 Mich App 449 (three circumstances where reliance on a warrant is objectively unreasonable)