Although not a driving case, the case of R. v. Phung is a useful reminder that officers should always describe their training and experience, both in their reports and in their testimony. Mr. Phung was arrested in Calgary following a period of surveillance during which a police officer believed he observed Mr. Phung engage in a drug transaction. The surveillance was prompted by tips by two informers making allegations about an Asian male engaged in drug dealing. The trial judge found the officer’s observations were insufficient by themselves to constitute reasonable and probable grounds to justify the arrest, but that, in the context of the informer tips and having regard to the officer’s experience as a police officer, there were grounds to make the arrest. The trial judge convicted Mr. Phung for eight offences, including possession of drugs, stolen property and weaponry.  The Alberta Court of Appeal dismissed his appeal. R. v. Phung, 2013 ABCA 63