Norman v. State

JOSEPH NORMAN, JR. v. STATE OF MARYLAND
Court of Appeals, Watts, March 27, 2017,
Car Stop- Odor of Marijuana- Without more, an odor of marijuana coming from a vehicle does not allow police to frisk the occupants

Plurality
(Main opinion- Watts with Hotten)
(Join in judgment only- Greene)
(Concur- Adkins with Barbera- not reasonable to believe passenger involved in drug dealing where car smells of mj)
(Dissent- Getty with McDonald – probable cause for drugs should be RAS to frisk)
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Robinson v. State

JERMAUL RONDELL ROBINSON v. STATE OF MARYLAND
DEXTER WILLIAMS v. STATE OF MARYLAND
VERNON HARVEY SPRIGGS, III v. STATE OF MARYLAND

Court of Appeals, Watts, Jan. 20, 2017,
Search – Police have probable cause to search a vehicle where they detect an odor of marijuana emanating from the vehicle

Following the CoSA opinion in Bowling
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Bowling v. State

JOSHUA PAUL BOWLING v. STATE OF MARYLAND
Court of Special Appeals, Graeff, Filed March 31, 2016,
CDS – Odor of Marijuana provides probable cause to believe evidence of “contraband or crime” is located within vehicle, thus justifying warrantless search without regard to quantity

Followed by CoA
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