See Bing, 551 Pa. at 668, 713 A.2d at 60. In reaching this determination, Bing found two cases instructive, Commonwealth v. Miller, 513 Pa. 118, 518 A.2d 1187 (1986), and Commonwealth v. Weidenmoyer, 518 Pa. 2, 539 A.2d 1291 (1988), where this Court refused, amid safety concerns, to reveal certain information that could have led to the disclosure of the confidential informant's identity. Most relevant for the purposes of the present appeal is the evidence that the Commonwealth presented in those matters.

"[S]ome courts have held that a citizen-informant who is the victim of or witness to a crime is presumed reliable. Commonwealth v. Weidenmoyer ([Pa.]1988), [ 518 Pa. 2] 539 A.2d 1291; State v. Ege (Neb. 1988), [ 227 Neb. 824] 420 N.W.2d 305. "In each of these cases, however, the court required that the witness or victim relate the basis for their knowledge or observations.

We note that in this case reliance by a police officer upon information provided by a fellow police officer was manifestly reasonable. See Commonwealth v.Weidenmoyer, 518 Pa. 2, 12-13 n. 6, 539 A.2d 1291, 1296 n. 6 (1988). C.

The only question that remains is whether the affidavit, when stripped of all references to the allegedly improper recordings, provided the magistrate with probable cause to issue the warrant. See, e.g. , Edmunds, 586 A.2d at 899 ("The linch-pin that has been developed to determine whether it is appropriate to issue a search warrant is the test of probable cause.") (internal citation and quotation omitted); see also Commonwealth v. Weidenmoyer , 518 Pa. 2, 539 A.2d 1291, 1296 (1988) ("the presence of some improper information in [an] affidavit is not enough to invalidate the search warrant if the warrant is also based upon other competent sources and is sufficient to constitute probable cause") (citations omitted). The parties dispute whether this standard has been met. Compare Appellant's Brief at 46-47 ("[w]hen [paragraphs 30-34, 38, and 41-44] are redacted from the affidavit, no present probable cause exists") with OAG's Brief at 17-19 (contending paragraphs 23, 26, 34, 42, 44, and 47 "clearly establish a nexus between [appellant]'s residence and illegal activity").

This Court has repeatedly rejected the argument that an officer relying on statements from an ordinary citizen, in contrastto a police informant, must establish the citizen's credibility and reliability. See, e.g., Commonwealth v. Weidenmoyer, 518 Pa. 2, 9–10, 539 A.2d 1291, 1295 (1988) (observing that an ordinary eyewitness, unlike a paid police informant, offers information out of concern for society or personal safety and, consequently, may be presumed credible and reliable); cf. Commonwealth v. Sudler, 496 Pa. 295, 305, 436 A.2d 1376, 1380–81 (1981) (noting this presumption applies absent circumstances indicating untrustworthiness). Moreover, while witness credibility and reliability are certainly appropriate considerations in determining probable cause, such technical pleading requirements are inconsistent with the practical, common sense determination of whether the totality of the circumstances presented in the affidavit establish a reasonable likelihood that evidence will be found.

There have been a few occasions since our decision in Gray, however, where our Court has used language differing from that used in the precedent discussed above. In Commonwealth v. Weidenmoyer, 518 Pa. 2, 9, 539 A.2d 1291, 1294 (1988), our Court, citing to Gates, stated that the determination of the issuing authority should be given "great deference," and in Torres, our Court also used the term "substantial deference" after initially articulating the standard of review as simple deference. However, these two isolated references, in and of themselves, do not alter the nearly uniform and consistent articulation by our Court of a standard of ordinary deference for appellate review of a magistrate's determination of probable cause for the issuance of a search warrant.

To be clear, we hold that, in reviewing probable cause, a police officer's training and experience is not a probable cause factor in the Lawson sense. If that were the case, the concept of probable cause as a constitutional barrier between the privacy of the citizen and unwarranted governmental intrusions would be undermined by an officer's ability to bootstrap a hunch based on constitutionally insufficient objective evidence simply by adverting to his experience as the foundation of his suspicion. While probable cause is a fluid concept, and requires only a showing that criminal activity may be reasonably inferred from a set of circumstances and need not be shown to, in fact, exist, Commonwealth v. Weidenmoyer, 518 Pa. 2, 13, 539 A.2d 1291, 1297 (1988), we must nonetheless remain true to its purposes, one of which is protecting citizens from arbitrary police intrusions. If we were to conclude that a police officer's experience was a factor to be added to every probable cause determination, rather than serve as a lens through which to view the facts, then every time an experienced officer begins a shift, probable cause begins to be assessed against all citizens every time they fall under the watchful eye of a suspicious officer who has been on the job for a meaningful period of time. The danger of this, of course, is the potential for innocent citizens being unlawfully seized and/or searched, i.e., being searched or seized with less than probable cause.

At the other end of the reliability continuum, this Court has acknowledged that the citizen witness who reports a crime is presumptively trustworthy. Commonwealth v. Weidenmoyer, 518 Pa. 2, 9-10, 539 A.2d 1291, 1295 (1988). This is so because a citizen informer:

At the other end of the reliability continuum, this Court has acknowledged that the citizen witness who reports a crime is presumptively trustworthy. Commonwealth v. Weidenmoyer, 518 Pa. 2, 9-10, 539 A.2d 1291, 1295 (1988). This is so because a citizen informer:

Id. at 132, 518 A.2d at 1195. Likewise, in Commonwealth v. Weidenmoyer, 518 Pa. 2, 539 A.2d 1291 (1988), the appellee sought the names of prior cases in which the informant involved in his case had provided information. At the suppression hearing, the state trooper refused to reveal the information, because members of a violent motorcycle gang had threatened reprisals against a witness in the appellee's case.