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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Utah v. Strieff

UTAH v. EDWARD JOSEPH STRIEFF, JR.
Supreme Court of the United States, Thomas, June 20, 2016,
Search – Exclusionary Rule – Evidence recovered from a suspect search incident to a valid arrest warrant need not be excluded even where the initial detention lacked reasonable suspicion

(Dissent – Sotomayor joined by Ginsburg for parts I-III – Starts by misstating the Court’s holding, then provides legitimate points related to a constitutional violation providing the basis for a constitutional search, then on her own discusses racial impact of unconstitutional policing)
(Dissent – Kagan with Ginsburg – Discovery of an arrest warrant after an unconstitutional stop is not an “intervening circumstance,” it is a product of the unconstitutional stop)
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United States v. Palmer

UNITED STATES OF AMERICA v. MICHAEL JEROME PALMER
US Court of Appeals for the Fourth Circuit, King, Filed April 21, 2016,
Search – Vehicle – Where RAS existed to suspect that a VA-required inspection-sticker mounted on the windshield was fraudulent, officer’s entry into the vehicle for purpose of examining the sticker was reasonable and did not constitute an unconstitutional search.

(Concur by Wynn – Taking time to run criminal background check was called for in this case, but is not part of a standard traffic stop)
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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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