Cited by

(“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.”).

The court of appeals determined that its 1984 precedential decision 5 of the search or it is reasonable to believe the vehicle contains evidence of the offense of arrest.” 556 U.S. at 351.

The state points out that “[t]he detec tion of odors alone, which trained police officers can identify as being illicit, constitute s probable cause to search automobiles for further evidence of crime.” see 5 Although the evid ence shows that the officers asked Waltz if they could search the car and she responded affirmatively, the state ha s never argued that Waltz consented to the search.

“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.” State v. Pierce , (citing 5 St.

See S (“It has long been held that the detection of odors alone .

“[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

“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 fo r further evidence of crime.”

In State v. P ierce, we stated that “[i]t 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.”

(stating that police officer’s trained detection of illicit odors establishes probable cause to suspect drug activity).

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

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)

“[T]he detection of odors alone, which trained police officers can identify as being illicit, constitutes probable cause to search automobiles for furthe r evidence of crime.”

tomobile exception); see also State v. Wicklund, 295 Minn. 403, 405, (observing a search was justified after two officers detected the odor of marijuana); (stating that the odor of marijuana has historically provided an officer with probable cause to search), aff’d, (“It ha s 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.”).

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 odors alone, which trained police officers can identify as being illicit, constitutes probable cause to search automobiles for further evidence of crime.”); State v. Wicklund, 295 Minn. 403, 405, (smell of burnt marijua

833 (Minn. App. 1984) (upholding stop of vehicle for “excessive muffler noise” and “noisy muffler”).

(“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.”).

See, (upholding search initiated due to loud muffler); (affirming conviction stemming from stop prompted by noisy muffler).

(holding that stop based on noisy muffler was lawful).

This court has determined that “the detection of odors alone, which trained police officers can identify as being illicit, constitutes probable cause to search * * (emphasis added); see also United States v. Ard, 731 F.2d 718, 723 (11th Cir.1984) (strong odor of marijuana around truck located in open field sufficient for finding of probable cause).

at 1630 ; -33 (Minn.Ct.App.1984).