Sanchez Vaughn, Trial Lawyers

02/07/2026

12/19/2025

For years in Florida’s Second District, the smell of ma*****na alone was often treated as enough to search a car.

That just changed.

In Williams v. State (Oct. 1, 2025), the Second DCA held that odor by itself is no longer probable cause for a vehicle search. Odor can still be a factor—but officers now need something more under the totality of the circumstances.

We broke down what the ruling means, where it applies (Hillsborough, Pinellas, Pasco, Polk, Manatee, Sarasota, and more), and why it matters for motions to suppress going forward.

Read the full update:

In Williams v. State (2025), Florida’s Second District Court of Appeal ruled that the smell of ma*****na alone no longer provides probable cause to search a vehicle. Learn how this decision reshapes search and seizure law across Hillsborough, Pinellas, Pasco, and nearby counties.