Michigan Supreme Court: “A warrantless search must be based on probable cause, and the smell of marijuana is insufficient to support probable cause.”

Michigan Supreme Court: “The Kazmierczak rule that the smell of marijuana alone is sufficient to support a finding of probable cause to believe a crime was being committed is no longer good law in light of the MRTMA. Instead, the appropriate rule is that the smell of marijuana is one factor that may play a role in the probable-cause determination.”