State of Arizona, Appellee v. Ian Harvey Cheatham, Appellant

Summary

The court held that, even after the Arizona Medical Marijuana Act, the odor of marijuana emanating from a vehicle established probable cause to believe the vehicle contained contraband or evidence of criminal activity. Because the officer had probable cause, the automobile exception authorized the warrantless vehicle search. The court affirmed the conviction and probationary term and vacated the court of appeals' opinion.