IN: Smell of meth was PC, aside from knowledge of purchase of precursors

Officers knew that defendant had bought precursors to make methamphetamine, and that they were likely in his car. There was enough information for probable cause for a search of the car, independent of what the officers smelled. The appellate argument is essentially an effort to get the court of appeals to reweigh the evidence which it cannot do under the standard of review. Holloway v. State, 2017 Ind. App. LEXIS 23 (Jan. 19, 2017).

The smell of marijuana and visible marijuana shake on the floorboard justified the search of the car. State v. Guein, 2017 Kan. App. LEXIS 9 (Jan. 20, 2017).* [Note: Also noteworthy is the fact the dashcam video was edited to keep something inadmissible out of the hearing of the jury, but only the edited version made it into the appellate record. The court is troubled by this, and defense counsel should have seen to it that the unedited version was in the record, too. It may not have mattered in the end, but it is discussed in the opinion.]