People v. Baker
In People v. Baker, 813 P.2d 331, 333 (Colo. 1991), police officers effected a valid warrantless entry of the defendant's home based upon probable cause and exigent circumstances.
After knocking on the defendant's door for the purpose of investigating an outstanding arrest warrant, police were greeted by the defendant.
The officers smelled the pungent odor of burning marijuana emanating from inside the house. The defendant attempted to warn someone else in the house that the police were at the door, then attempted to shut the door.
The police then entered the home and discovered evidence of drug possession and use. See Baker, 813 P.2d at 332.
The Court held that under those circumstances, "the officers had probable cause to believe a crime was being committed when they smelled burned marijuana." Id. at 333.