In State v. Steelman, 93 S.W. 3d 102 (Tex.Crim.App. 2002), the Court held that the smell of burned marijuana does not, by itself, present a sufficient basis for probable cause to enter a private residence and arrest an individual. In Steelman, the Abilene Police received a tip of drug dealing originating from the Steelman's residence. Upon arrival at Steelman's home, the police looked through a window but were unable to see any illegal activity. The officers then knocked on the door. When Steelman opened the door, the officers smelled the odor of burned marijuana. Steelman tried to close the door, but an officer placed his foot in the doorway and eventually forced his way into the residence. Once inside the residence, the officers arrested everyone within the home. Id. Up to this point, the officers did not have a warrant nor had they obtained consent to enter the residence. At the conclusion of a pretrial suppression hearing, the trial court found that the warrantless arrest of Steelman was illegal since the odor of marijuana, standing alone, did not provide sufficient probable cause to lead officers to believe that Steelman had committed an offense in their presence. The trial court granted the motion to suppress pursuant to TEX. CRIM. PROC. CODE ANN. 14.01(b) (Vernon 1977), finding that the State had failed to prove that an offense had been committed in the officer's presence. Id. at 106. The trial court held that once an officer arrests a person without a warrant or without observing an offense, any evidence obtained after the arrest must be suppressed. Id. at 105. The Court of Criminal Appeals upheld the decision of the trial court, stating that the odor of marijuana, standing alone, does not authorize a warrantless search or seizure of a home. Id. at 108.