State v. Miller, 254 Or. App. 514

Defendant was convicted on multiple drug offenses: three counts of delivery of methamphetamine (Counts 2–4), possession of methamphetamine (Count 5), possession of marijuana (Count 6), possession of a Schedule II controlled substance (Count 7), and possession of a Schedule I controlled substance (Count 8); criminal forfeiture was allowed in Count 9.
The trial court denied his request for self-representation and denied suppression of evidence obtained from a warrantless search that the defense challenged as unsupported by probable cause.
On appeal, defendant challenged (1) the denial of his right to self-representation and (2) the denial of his suppression motion.
The appellate court reversed and remanded Counts 2–9 for a new trial due to the self-representation error; it also partially remanded with guidance on suppression, finding the residence evidence suppressible but the vehicle evidence admissible.
The suppression ruling rested on the credibility and basis for the UI’s statements and the nexus between the residence and the alleged drug activity; the acquittal on Count 1 is noted.
In remand, the court noted it would reassess suppression on remand and that the conviction on Counts 2–8 and the forfeiture would be reconsidered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court err by denying self-representation?	Blanchard: right to self-representation must be analyzed on the record.	Davis: waiver not knowingly intelligent; court denied self-representation summarily.	Yes; reversal and remand for Counts 2–9.
Was the affidavit sufficient to establish probable cause for the residence search?	Keerins/Wilson: nexus to residence lacking; UI statements not adequately supported.	Hatten's training/experience failed to tie residence to drug activity.	No for residence; suppression reversed for residence evidence; vehicle search upheld.

State v. Duarte / Knull-Dunagan, 237 Or App 13 (Or. App. 2010) (probable-cause review limited to uncontroverted facts and inferences from the warrant)
State v. Castilleja, 345 Or 255 (Or. 2008) (probable-cause standard in warrant affidavits)
State v. Wilson, 178 Or App 163 (Or. App. 2001) (affidavit must connect facts to probable cause; deference to magistrate)
State v. Keerins, 197 Or App 428 (Or. App. 2005) (limits of training-and-experience nexus to residence)
State v. Blanchard, 236 Or App 472 (Or. App. 2010) (right to self-representation under state and federal constitutions; trial court error when denied)