Norman v. State

At issue in this case was whether a law enforcement officer who detects an odor of marijuana emanating from a vehicle with multiple occupants has reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and thus may frisk the vehicle’s occupants for weapons. The circuit court denied Defendant’s motion to suppress in this case, concluding that the police officer that searched the vehicle in which Defendant was a passenger had reasonable articulable suspicion that Defendant was armed and dangerous. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) an odor of marijuana alone emanating from a vehicle with multiple occupants does not give rise to a reasonable articulable suspicion that the vehicle’s occupants are armed and dangerous and subject to frisk; and (2) at the time of the frisk in this case, there were insufficient circumstances giving rise to reasonable articulable suspicion that Defendant was armed and dangerous to justify the frisk. View "Norman v. State" on Justia Law