Florida District Court of Appeal · 2025
State v. Simpson
The smell of fresh cannabis, combined with the officers' narcotics experience and the area's documented drug activity, gave probable cause to search the car under the automobile exception. The court stressed this was NOT a smell-alone ruling — it upheld the search on the totality of the circumstances.
414 So. 3d 291 (Fla. 6th DCA 2025)
Find the opinion for State v. SimpsonFlorida District Court of Appeal · 2018
Wooden v. State
The question is not whether the ticket was written yet — it is whether the sniff added time. If it did, you need reasonable suspicion in the record or the case is gone.
244 So. 3d 1170 (Fla. 1st DCA 2018)
Find the opinion for Wooden v. StateFlorida District Court of Appeal · 2025
Williams v. State
In the 2d DCA the smell of cannabis by itself no longer justifies a vehicle search — it is one factor. Build the totality before you go in.
Williams v. State, No. 2D2023-2200, 2025 WL 2799622 (Fla. 2d DCA Oct. 1, 2025) (en banc)
Find the opinion for Williams v. StateEach summary was checked against the court’s majority opinion on September 30, 2026. Read the decision and follow your agency’s policy; this is reference guidance, not legal advice.