State of Vermont v. Edwin A. Towne

Summary

The court affirmed the first-degree murder conviction, holding that the search warrant, nontestimonial identification order, custodial statements, arrest, and charging information were legally valid. It rejected a rigid more-likely-than-not formulation of probable cause, applied a common-sense totality-of-the-circumstances approach, and found sufficient factual connections between the defendant, the crime, the murder weapon, and the searched locations. The court also held that the defendant knowingly waived his Miranda rights, that state officers could make a warrantless arrest for a federal felony when authorized by state law, and that the information adequately charged first-degree murder. Morse, J., concurring, would have retained the more-likely-than-not probable-cause standard in this case rather than overruling it.