People v. Redmond

Summary

The Illinois Supreme Court held that, after cannabis legalization, the odor of burnt cannabis alone does not establish probable cause for a warrantless vehicle search. Although the odor may contribute to the totality-of-the-circumstances analysis and justified further investigation, the additional facts known to the officer did not make it sufficiently probable that the vehicle contained evidence of criminal activity. The court therefore affirmed suppression of the cannabis seized from Redmond's vehicle.