State v. Crocker
In State v. Crocker, 97 P.3d 93 (Alaska App. 2004), the Court ruled that the search warrant application in that case demonstrated probable cause that marijuana was being grown in the defendant's home, but the application did not provide any information that the defendant was cultivating more than four ounces.
Although the application asserted that the smell of growing marijuana was "strong," the Court noted that the application contained no assertion that the strength of the smell gave the officers any indication of the amount of marijuana that might be growing inside, or that a correlation could be drawn between the strength of the odor of growing marijuana and the amount of marijuana being grown.
The Court held that a magistrate should not issue a warrant to search someone's home for evidence of marijuana possession unless the search warrant application establishes probable cause to believe that the marijuana possession falls outside the scope of protected personal use recognized by the Alaska Supreme Court in Ravin v. State, 537 P.2d 494 (Alaska 1975) -- e.g., the marijuana is being cultivated for sale, or the amount of marijuana exceeds the amount allowed for personal use. Crocker, 97 P.3d at 97-98.