SC: Three psuedo buys in one day was RS, and the smell of ammonia at his house justified a protective sweep

Defendant’s three purchases of pseudoephedrine in one day was reasonable suspicion that he had a meth lab to support a protective sweep because, when the dwelling door was opened, the smell of ammonia was overwhelming. State v. Kotowski, 2019 S.C. App. LEXIS 45 (May 16, 2019).*

A USFS officer had reasonable suspicion to contact defendant for an alleged illegal campfire during a period of restriction on campfires. The smell of marijuana allowed the officer to extend the stop. United States v. Eaton, 2019 U.S. Dist. LEXIS 82648 (D. Ariz. May 16, 2019).*

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