Officers approaching defendant’s house could smell marijuana. When the door was opened, the smell got stronger, and that justified a warrantless entry. State v. Ott, 2017 W. Va. LEXIS 256 (April 10, 2017) (memorandum).
The CI never said he was 100% sure about the facts he passed on, and he qualified the second-hand information. He was texting the officer, and the information was contemporaneous eyewitness information. United States v. Palmer, 2017 U.S. Dist. LEXIS 53496 (E.D. Pa. April 7, 2017).*