Brief Brief: State v. Grant, 449 Md. 1 (2016).
HOLDING: The Maryland Court of Appeals had held that a police officer, who inserts his head into a passenger side window of a defendant’s vehicle during a traffic stop, conducted a search under the Fourth Amendment, ( State v. Grant 449 Md. 1 (2016)). In Grant, the court found that the detection of odor of marihuana from the Officer sticking his head through the window, exceeded permissible scope of the stop. ( Id. )