In United States v. Nielsen (C.A.10, 1993), 9 F.3d 1487, the Court held that the "odor of burnt marijuana in the passenger compartment of a vehicle does not, standing alone, establish probable cause for a warrantless search of the trunk of a vehicle." Farris, 109 Ohio St. 3d 519, 2006 Ohio 3255, P 52, 849 N.E.2d 985. This proposition is established by the common sense observation that an odor of burning marijuana would not create an inference that burning marijuana was located in a trunk. Nielsen explicitly limited the scope of a search to the passenger compartment because that was the place from which the officer smelled burnt marijuana. Because a warrantless search of an automobile "is defined by the object of the search and the places in which there is probable cause to believe that it may be found," the smell of burnt marijuana does not provide probable cause to search a trunk. Nielsen, 9 F.3d at 1491.