What is the burden of proving probable cause for arrest at a Mapp hearing?

At a Mapp hearing, the People have the burden of initially going forward and establishing the legality of the search and seizure of the property recovered. Here, they must also demonstrate how that recovery provided them with probable cause to arrest the defendant. The burden then shifts to the defendant to prove by preponderance of the evidence that the police conduct was illegal. See generally, People v. Scott, 2009 NY Slip Op 52191(U) (Dist Ct, Nassau County 2009).