Officer Cannot Stick Head in Car Window to take a Sniff. State v. Grant.


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. )


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