Blake v. State
In Blake v. State 772 So. 2d 1200 (Ala. Crim. App. 2000), the Alabama Court of Criminal Appeals held that the odor of burning marijuana coming from a vehicle provides probable cause both to search the vehicle and to arrest the occupants of the vehicle.
The Court explained, "Under the facts of this case, where two persons were sitting in the front seat of an automobile, we do not believe that an individualized suspicion was required to arrest either Blake or his passenger. To require such individual suspicion in all cases would be to say that even where the odor of burning marijuana is emanating from the relatively close confines of an automobile -- therefore clearly justifying a search of the automobile -- if the occupants of the vehicle have the foresight to quickly secrete the controlled substance in their pockets, they may drive away after the search of the vehicle proves fruitless." Id. at 1206-07.