LA5: Motorist assist led to plain smell and valid search

Police were called for a motorist assist to unlock a car. Once opened, the car smelled of marijuana, and that created probable cause. The police were invited to the curtilage. State v. Keller, 2022 La. App. LEXIS 247 (La. App. 5 Cir. Feb. 1, 2022).

Defendant was stopped for a missing front license plate. Defendant admitted that he had marijuana in the car, and one thing led to another and there was probable cause to search. The grant of the motion to suppress is reversed. United States v. Stokes, 2022 U.S. App. LEXIS 4325 (9th Cir. Feb. 17, 2022).*

“Here, the trooper had reasonable articulable suspicion that Louallen was involved in criminal activity — other than mere traffic violations — when the trooper initiated the traffic stop.” Therefore, the stop was lawfully extended. Louallen v. State, 2022 Ga. App. LEXIS 84 (Feb. 17, 2022).*

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