Cited by

18, 919 (Minn. 1980) (holding that search of a vehicle “was justified by the motor vehicle exception to the warrant requirement”) ; State v. Johnson , (holding that deputy who saw marijuana plants in the trunk of a car had sufficient facts to “reasonably believe that there might be additional marijuana located in other areas of [the] car”); (noting that officer who “smelled the odor of marijuana emanating from the passenger compartment .

We noted that, at the time Wicklund was 4 See, (citing Wicklund for the proposition that “the odor of marijuana” justified a “warrantless search of the passenger compartment for marijuana pursuant to the so-called motor vehicle exception to the warrant requirement”); (citing Wicklund for the prop

This court considered the impact that the odor of marijuana has in a probable cause determination in 13 (per curiam), supports its argument that probable cause to search under the automobile exception can be supported solely by the odor of marijuana.

detected the distinct odor of marijuana, they had probable cause to believe that the vehicles contained contraband”); (holding that if an officer “smelled the odor of marijuana emanating from the passenger compartment [of a vehicle] .

See State v. Schultz , (stating that the automobile exception applies when an officer smells marijuana emanating from a car) ; (holding that a vehicle search was justified because the officer “detected a ‘strong’ and ‘overwhelming’ odor of marijuana emanat

See State v. Schultz , (stating that the automobile exception applies when an officer smells marijuana emanating from a car).

“[T]he detection of odors alone, which trained police officers can identify as being illicit, constitutes probable cause to search aut omobiles for further evidence of crime.” see also State v. Schultz , d 836, 837 (Minn. 1978); State v. Hodgman

State v. Schultz , ; State v. Hodgman

for the pro position that an officer’s discovery of some contraband in a car provides probable cause to search for more contraband.

To support the conclusion that the odor of marijuana from the vehicle provided the officer with probable cause to search Hughes’s person, d 829, 833 (Minn. App. 1984), and State v. Ortega (Ortega I)

(stating that if an officer smelled marijuana before searching a vehicle then the search was justified under the automobile exception); see also State v. Wicklund, 295 Minn. 403, 405, (observing a search was justified after two officers detected the odor of marijuana); S

See, (upholding car search under automobile exception based on marijuana odor ); State v. Ortega , (same), aff’d

(noting that officer properly conducted warrantless search of vehicle for marijuana where officer smelled marijuana emanating from the passenger compartment before the search); State v. Wicklund, 295 Minn. 403, 405, (upholding warrantless search of vehicle after officer

see also Ortega, d at 854 (clarifying that probable cause is a reasonableness test and applies regardless of the amount of marijuana found on driver), aff’d, (“It has long been held that the detection of

(“It has long been held that the detection of odors alone, which trained police officers can identify as being illicit, constitutes probable cause to search automobiles for further evidence of crime.”).

of some marijuana in a (reversing an order erroneously suppressing evidence seized in a warrantless search of the passenger compartment of a motor vehicle after the police lawfully approached the defendant’s car, smelled burning marijuana and saw a marijuana pipe being passed), (holding that officer, who smelled marijuana emanating from lawfully stopped vehicle, had a right to search passenger compartment for marijuana pursuant to motor vehicle exception).