The smell of marijuana from a car in Nevada where recreational use is permitted is still probable cause because state law doesn’t permit smoking in a car. United States v. Gray, 2019 U.S. App. LEXIS 19095 (9th Cir. June 26, 2019).
It wasn’t apparent to anybody that entry into plaintiff’s private club was limited to members because there were no signs or bouncers to control or limit access. The officers get qualified immunity on the claim they unlawfully entered the premises to conduct an administrative search under state law. Brown v. City of Atlanta, 2019 U.S. App. LEXIS 18844 (11th Cir. June 25, 2019).*