W.D.Okla.: Strong chemical smell, likely meth production, was PC in affidavit for search warrant

Strong chemical smell outside a building to a trained officer was probable cause for issuance of a search warrant for the house for meth. United States v. Collins, 2012 U.S. Dist. LEXIS 74639 (W.D. Okla. May 30, 2012):

The officer reporting the smell in this case, Undersheriff King, had attended both DEA and OBN schools regarding methamphetamine laboratories. Although it could have been more specific, the search warrant affidavit did state that the undersheriff was able to identify the odor because of his “training [and] experience with methamphetamines lab.” Search Warrant, Attachment “B.” As noted by defendant Smith, the affidavit did not specify the exact source of the odor. However, it is apparent that the smell was coming from a building on the Smith property and not a field (“drove by described residence in Attachment “A,” and detected a very strong odor of Anhydrous Ammonia and Ether”). The affidavit also was not defective for failing to explicitly link the odor to a crime, since the specific chemical odor that is identified is commonly linked to the manufacture of methamphetamine. While the affidavit submitted to the state judge was certainly bare bones, the court concludes it was sufficient, in light of the flexible standard referenced above, to support issuance of the warrant.