In People v. Gibbs (1971) 16 Cal.App.3d 758, the arresting officer stopped defendant's vehicle because it was emitting excessive exhaust smoke in violation of Vehicle Code section 27153. Upon approaching the vehicle the officer saw, in plain view, a marijuana cigarette in the passenger compartment of the car. A further search yielded other narcotics and dangerous drugs. On appeal the defendant challenged the constitutionality of the Vehicle Code section. The court held that the constitutionality of section 27153 was not relevant to a determination of probable cause for an arrest.