State v. Dalland
Annotate this CaseDefendant was convicted of possession of a controlled substance. Defendant appealed the denial of his motion to suppress, arguing that the State did not have probable cause to conduct a warrantless search of his vehicle based on the odor of marijuana emanating from his person or on a police officer’s alleged knowledge that there were needles used for methamphetamine in Defendant’s vehicle. The court of appeals reversed, concluding (1) standing alone, the fact that Defendant smelled of burnt marijuana did not provide probable cause to search Defendant’s vehicle; and (2) the officer’s alleged knowledge of the needles in Defendant’s car was based solely on testimony that should be disregarded as a matter of law. The Supreme Court reversed, holding (1) the court of appeals should have given deference to the district court’s finding of fact that the officer was told about the needles prior to the search; and (2) probable cause existed for the search based on the combined facts that Defendant smelled of burnt marijuana and that he admitted prior to the search of his vehicle to having needles in the vehicle.
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