Norman v. State’s Empirical Analysis

Citation profile

25 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “odor of marijuana alone emanating from a vehicle with multiple occupants does not give rise to reasonable articulable suspicion that the vehicle's occupants are armed and dangerous and subject to frisk.”

   2 later decisions quote this exact passage
   e.g. 237 Md. App. 661 - Lewis v. State · 232 Md. App. 241 - Johnson v. State

2. “It is correct that, in Robinson , [451 Md.] at 131-32 [ 152 A.3d 661 ], this Court concluded that law enforcement officers are unable to differentiate between a criminal amount (ten grams or more) and a non-criminal amount (less than ten grams) of marijuana based on the odor of marijuana. Norman takes out of context the significance of this Court's statement that the odor of marijuana may be indicative of possession of less than ten grams of marijuana. This Court made the statement in the context of holding that an odor of marijuana gives rise to probable cause to search a vehicle, and for purposes of probable cause to search a vehicle there is no distinction between the presence of more than ten grams of marijuana and less than ten grams of marijuana in the vehicle. * * * Furthermore, at the risk of stating the obvious, Robinson in no way addressed whether the odor of marijuana gives rise to reasonable articulable suspicion to frisk . * * * At the same time, however, Robinson does not stand for the proposition that the odor of marijuana alone emanating from a vehicle gives rise to reasonable articulable suspicion that every occupant of a vehicle is armed and dangerous . In contrast to Norman's reading of Robinson , the State expands Robinson 's holding to argue that it enables a law enforcement officer to conclude that, based solely on the odor of marijuana emanating from a vehicle, it is reasonable to believe that all of the vehicle's occupants are armed and dangerous and t”

   1 later decision quote this exact passage · from the dissent
   e.g. 237 Md. App. 661 - Lewis v. State

3. “the court ... must not parse out each individual circumstance for separate consideration. In making its assessment, the court should give due deference to the training and experience of the law enforcement officer who engaged the stop at issue. Such deference allows officers to draw on their own experience and specialized training to make inferences from and deductions about the cumulative information available to them that might well elude an untrained person. To be sure, [a] factor that, by itself, may be entirely neutral and innocent, can, when viewed in combination with other circumstances, raise a legitimate suspicion in the mind of an experienced officer.”

   1 later decision quote this exact passage
   e.g. 235 Md. App. 263 - Goodwin v. State