NY co.ct.: Noting split in case law, slight smell of MJ in the passenger compartment generally doesn’t justify a search of the trunk; here, however, trunk accessible from inside car

Noting a split in authorities, the court finds that the smell of marijuana in the passenger compartment [here, coming off the rental agreement] does not give probable cause to search the trunk. Here, however, the trunk was accessible from the interior, too, and that justifies this search. People v. Jones, 2016 NY Slip Op 26365, 2016 N.Y. Misc. LEXIS 4160 (Livingston Co. Nov. 4, 2016).

A 911 call from a citizen informant was reasonable suspicion for the encounter with defendant at her door about her driving under the influence. The officer arrived at her door within minutes, and he’d also talked to the citizen informant. Cook v. State, 2016 Tex. App. LEXIS 12169 (Tex. App. – Ft. Worth Nov. 10, 2016).*