Cameron v. Alabama
In Cameron v. Alabama, 861 So. 2d 1145 (Ala. Crim. App. 2003), a police officer approached an apartment in a public housing project because the Housing Authority had notified the police that a vehicle was parked on its front lawn and needed to be moved.
When someone opened the door, the officer could smell marijuana and see smoke in the apartment. The officer asked to speak to the tenant of the apartment, at which point the person who had opened the door ran into the kitchen.
The officer then entered the apartment and observed the person remove objects from the kitchen table and place them in a drawer. A subsequent consent search resulted in the seizure of marijuana.
The Alabama Court determined that the warrantless entry was justified by exigent circumstances. The court first reasoned that the odor of marijuana gave the officer probable cause to believe that there was marijuana in the apartment. 861 So. 2d at 1150.
The court next considered that the person who opened the door ran from it and began to hide things. Id. at 1152.
Finally, the court observed that the officer had approached the apartment "for a legitimate and uncontrived reason." Id.
The court concluded that "taking all of this into consideration, the officer could have reasonably concluded from the person's suspicious actions that he would likely destroy or remove some portion of the marijuana." Id.