A statute passed a year after this search that the odor of marijuana was no longer probable cause didn’t apply retroactively here. It says “in violation of this statute,” so that’s prospective only. Loeper v. Commonwealth, 2023 Va. App. LEXIS 44 (Jan. 24, 2023) (unpublished).
Driving below the speed limit at 3 am and weaving was reasonable suspicion for a stop. Swann v. Commonwealth, 2023 Va. App. LEXIS 46 (Jan. 24, 2023).*
Consent after a protective sweep isn’t involuntary. United States v. Touray, 2022 U.S. Dist. LEXIS 236548 (N.D. Ga. Dec. 22, 2022),* adopted 2023 U.S. Dist. LEXIS 11519 (N.D. Ga. Jan. 24, 2023).*