What is the test for establishing probable cause for the arrest of a man accused of possessing cocaine base?

cocaine base was insufficient to establish probable cause for his arrest. Just as "presence under a particular set of circumstances" evidencing constructive possession may support a conviction, United States v. Soto, 959 F.2d 1181, 1185 (2d Cir. 1992); see also United States v. Rios, 856 F.2d 493, 496 (2d Cir. 1988) (requiring "sufficient indicia of dominion and control" to support possession conviction), the circumstances of a defendant's presence may satisfy the less demanding standard of probable cause, see generally Walczyk v. Rio, 496 F.3d 139, 156-57 (2d Cir. 2007) (collecting cases holding that probable cause is a fluid concept requiring more than mere suspicion but not a prima facie showing of criminality).