Robinson, Williams & Spriggs v. StateAnnotate this Case
Before October 1, 2014, under Maryland law, possession of less than ten grams of marijuana was a misdemeanor that carried a maximum penalty of ninety days of incarceration and a fine of $500. As of that date, possession of less than ten grams of marijuana became a civil offense punishable by participation in a drug education program, an assessment for substance abuse disorder, possible substance abuse treatment, and a fine. In separate cases, each of three petitioners moved to suppress evidence that had been found in a vehicle that he had been driving or had possession of, arguing that, due to decriminalization of possession of less than ten grams of marijuana, a law enforcement officer no longer has probable cause to search a vehicle when the officer detects an order of marijuana emanating from the vehicle. The circuit court denied the motion to suppress in each case. The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) notwithstanding the decriminalization of less than ten grams of marijuana, marijuana remains contraband, and the order of marijuana gives rise to probable cause to believe that the vehicle contains contraband or evidence of a crime; and (2) there was probable cause to search the vehicles in question in this case.