Arrests generally must be supported by the same level of probable cause, with or without a warrant. (Whiteley v. Warden, Wyoming State Penitentiary) A detached and neutral magistrate must find probable cause before a warrant for an arrest may be issued. In determining the sufficiency of an affidavit supporting an arrest warrant, a reviewing court is limited to the “four corners” of the affidavit. Affidavits are viewed in a common sense manner. A presumption is indulged in favor of the regularity of the proceedings in a lower court unless the record presents aff. evidence to the contrary.
The failure to appear in court is a unique offense for purposes of issuing a warrant. By its very nature, a defendant’s failure to appear is within the court’s personal knowledge. The trial court issuing each of the warrants in this case was supplied with sufficient information to support an independent judgment that probable cause existed for the warrants. Therefore, the fact that appellant had several outstanding warrants gave the officers probable cause to arrest him.