Defendant responded to a knock at his door, and answering the knock is not implied consent to enter. Officers couldn’t rely on defendant’s probation search waiver because they weren’t aware of it. “ Moreover, viewed in the light most favorable to the State, the evidence shows that, when the agents subsequently requested permission to enter, Little made no effort to engage in any discussion of the matter and instead continued to back up into the camper and turn his back on the agents.” That was mere acquiescence. Little v. State, 2020 Ga. App. LEXIS 37 (Feb. 10, 2020).
The smell of burnt marijuana justified the search of the passenger compartment which led to contraband and that led to the trunk. State v. Braxton, 2020-Ohio-424, 2020 Ohio App. LEXIS 380 (12th Dist. Feb. 12, 2020).*