Defendant was convicted in Circuit Court, Pinellas County, Ray E. Ulmer, Jr., J., of felony possession of marijuana. Defendant appealed. On motion for rehearing, the District Court of Appeal, 793 So.2d 976, affirmed in part, reversed in part, and remanded. Review was granted. The Supreme Court, Lewis, J., held that officer's detection of very strong odor of previously-burnt marijuana coming directly out of rolled-down window of defendant's vehicle, combined with other suspicious circumstances, provided probable cause to search the entire vehicle, including the trunk.
State v. Betz, 815 So. 2d 627 (Fla. 2002)
Holding: Officers may have probable cause to search the entire vehicle including the trunk as long as they believe incrimidating evidence could be found in the vehicle.