MD: Odor of MJ from car alone doesn’t provide RS for a frisk for weapons

The odor of marijuana alone doesn’t provide reasonable suspicion for a frisk for weapons. Norman v. State, 2017 Md. LEXIS 153 (March 27, 2017):

Where the odor of marijuana emanates from vehicle with multiple occupants, law enforcement officer may frisk, i.e., pat down, occupant of vehicle if additional circumstance or circumstances give rise to reasonable articulable suspicion that occupant is armed and dangerous. Stated otherwise, Court of Appeals held that, for law enforcement officer to have reasonable articulable suspicion to frisk one of multiple occupants of vehicle from which odor of marijuana is emanating, totality of circumstances must indicate that occupant in question is armed and dangerous. Odor of marijuana alone emanating from vehicle with multiple occupants does not give rise to reasonable articulable suspicion that vehicle’s occupants are armed and dangerous and subject to frisk.