text:
Jermaul Rondell Robinson v. State of Maryland, No. 37, September Term, 2016; Dexter
 Williams v. State of Maryland, No. 39, September Term, 2016; Vernon Harvey Spriggs,
 III v. State of Maryland, No. 46, September Term, 2016
 ODOR OF MARIJUANA – PROBABLE CAUSE – CARROLL DOCTRINE –
 SEARCH OF VEHICLE – DECRIMINALIZATION OF POSSESSION OF LESS
 THAN TEN GRAMS OF MARIJUANA – Court of Appeals held that law enforcement
 officer has probable cause to search vehicle where law enforcement officer detects odor of
 marijuana emanating from vehicle, as marijuana in any amount remains contraband,
 notwithstanding decriminalization of possession of less than ten grams of marijuana; and
 odor of marijuana gives rise to probable cause to believe that vehicle contains contraband
 or evidence of crime. There was probable cause to search vehicles in question, based on
 law enforcement officers having detected odor of marijuana coming from vehicles that
 Petitioners had been driving or in possession of.
 Circuit Court for Baltimore City
 Case No. 815049029
 IN THE COURT OF APPEALS
 Circuit Court for Baltimore City
 Case No. 815147025 OF MARYLAND
 Circuit Court for Dorchester County Nos. 37, 39, & 46
 Case No. 09-K-14-015452
 September Term, 2016
 Argued: December 1, 2016
 ______________________________________
 JERMAUL RONDELL ROBINSON
 v.
 STATE OF MARYLAND
 ______________________________________
 DEXTER WILLIAMS
 v.
 STATE OF MARYLAND
 ______________________________________
 VERNON HARVEY SPRIGGS, III
 v.
 STATE OF MARYLAND
 ______________________________________
 Barbera, C.J.
 Greene
 Adkins
 McDonald
 Watts
 Hotten
 Getty,
 JJ.
 ______________________________________
 Opinion by Watts, J.
 ______________________________________
 Filed: January 20, 2017
 In 2014, Maryland joined a number of other jurisdictions that have decriminalized,
 but not legalized, possession of small amounts of marijuana—that is, under the law of these
 jurisdictions, possession of a small amount of marijuana remains illegal, but is punishable
 by a fine, not by incarceration.1 Before October 1, 2014, under Maryland law, possession
 of less than ten grams of marijuana was a misdemeanor that carried a maximum penalty of
 ninety days of incarceration and a fine of $500. See 2014 Md. Laws. 1119 (Vol. II, Ch.
 158, S.B. 364); Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2013 Supp.) § 5-
 601(c)(2)(ii). As of October 1, 2014, under Maryland law, possession of less than ten
 1
 Under the following fifteen jurisdictions’ laws, first-time possession of a small
 amount of marijuana is punishable only by a fine and/or participation in an examination,
 drug education, or drug treatment: Connecticut, Delaware, Illinois, Maine, Maryland,
 Minnesota, Mississippi, Missouri, Nebraska, Nevada, New York, North Carolina, Ohio,
 Rhode Island, and Vermont. See Conn. Gen. Stat. § 21a-279a(a)(1); Del. Code Ann. tit.
 16 § 4764(c); 720 Ill. Comp. Stat. 550/4(a); Me. Stat. tit. 22 § 2383(1)(A); Md. Code Ann.,
 Crim. Law (2002, 2012 Repl. Vol., 2016 Supp.) § 5-601(c)(2)(ii); Minn. Stat. § 152.027
 Subd. 4(a); Miss. Code Ann. § 41-29-139(c)(2)(A)(1); Mo. S.B. 491 (2014), available at
 http://www.senate.mo.gov/14info/BTS_Web/Bill.aspx?SessionType=R&BillID=277235
 23 [https://perma.cc/J672-URZH]; Neb. Rev. St. § 28-416(13)(a); Nev. Rev. Stat. §
 453.336(4)(a); N.Y. Penal Law § 221.05; N.C. Gen. Stat. § 90-95(d)(4); Ohio Rev. Code
 Ann. § 2925.11(C)(3)(a); 1956 R.I. Gen. Laws § 21-28-4.01(c)(2)(iii); Vt. Stat. Ann. tit.
 18 § 4230a(a)(1).
 Six jurisdictions—Alaska, California, Colorado, the District of Columbia,
 Massachusetts, and Oregon—have legalized possession of a small amount of marijuana.
 See Alaska Stat. Ann. § 17.38.020(1); 2016 Cal. Legis. Serv. Prop. 64 § 4.4; Colo. Const.
 Art. 18, § 16(3)(a); DC Code Ann. § 48-904.01(a)(1)(A); Massachusetts Law about
 Marijuana Possession, Massachusetts Trial Court Law Libraries (updated Nov. 14, 2016),
 http://www.mass.gov/courts/case-legal-res/law-lib/laws-by-subj/about/marijuana.
 html [https://perma.cc/X7RE-D3HW]; Or. Rev. Stat Ann. § 475.864.
 Possession of marijuana in any amount, however, remains a crime under federal
 law. See 21 U.S.C. § 844(a).
 grams of marijuana became “a civil offense”2 that is punishable by participation in a drug
 education program, an assessment for substance abuse disorder, possible substance abuse
 treatment, and a fine, the amount of which depends on whether the violation is a first,
 second, or subsequent violation of the statute. See 2014 Md. Laws. 1119, 1124 (Vol. II,
 Ch. 158, S.B. 364); Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2014 Supp.) § 5-
 601(c)(2).
 Here, Jermaul Rondell Robinson (“Robinson”), Dexter Williams (“Williams”), and
 Vernon Harvey Spriggs, III (“Spriggs”) (together, “Petitioners”) contend that, due to the
 decriminalization of possession of less than ten grams of marijuana, a law enforcement
 officer no longer has probable cause to search a vehicle where the law enforcement officer
 detects an odor of marijuana emanating from the vehicle. In separate cases, each Petitioner
 moved to suppress evidence that had been found in a vehicle that he had been driving or
 had possession of. In each case, at a hearing on the motion to suppress, a law enforcement
 officer testified that either a strong odor or an overwhelming odor of fresh marijuana was
 emanating from the car that the Petitioner had been using. In each case, the circuit court
 denied the motion to suppress, and each Petitioner was convicted of possession of at least
 ten grams of marijuana under the amended statute. Petitioners appealed, and, in each case,
 the Court of Special Appeals affirmed the circuit court’s judgment in an unreported
 opinion. Petitioners separately filed petitions for writs of certiorari, which this Court
 2
 As discussed below, Maryland law provides a limited authorization for certain
 eligible persons to possess and/or use marijuana for medical purposes. Possession and/or
 use of medical marijuana is not at issue in these cases.
 -2-
 granted. We heard one oral argument as to Petitioners’ cases on the same day, and this
 opinion serves to consolidate the cases.
 Petitioners raise an important matter of first impression: whether, in light of the
 decriminalization of possession of less than ten grams of marijuana, a law enforcement
 officer has probable cause to search a vehicle upon detecting an odor of marijuana
 emanating from the vehicle. In a reported opinion in an earlier case—Bowling v. State,
 227 Md. App. 460, 476, 134 A.3d 388, 398, cert. denied, 448 Md. 724, 141 A.3d 135
 (2016)—the Court of Special Appeals held that the decriminalization of possession of less
 than ten grams of marijuana did not undermine the principle that the alert of a narcotics
 dog, that is certified to detect marijuana along with other controlled dangerous substances,
 constitutes probable cause to search a vehicle. In each of Petitioners’ cases, the Court of
 Special Appeals applied Bowling and concluded that a law enforcement officer’s detection
 of a strong odor of marijuana coming from a vehicle that the defendant possessed provides
 probable cause to search the vehicle, despite the decriminalization of possession of less
 than ten grams of marijuana, because marijuana in any amount remains contraband—i.e.,
 goods that are illegal, but not necessarily criminal, to possess. In addition to the holding
 of the Court of Special Appeals in Bowling, courts in Maine, Oregon, California,
 Minnesota and Colorado have reached similar conclusions, namely, that where an officer
 detects the odor of marijuana coming from a vehicle, the warrantless search of the vehicle
 is permitted, even though these jurisdictions had decriminalized—and, in at least one
 instance, legalized—the possession of a small quantity of marijuana. See State v. Barclay,
 398 A.2d 794 (Me. 1979); State v. Smalley, 225 P.3d 844 (Or. App. 2010); People v.
 -3-
 Waxler, 224 Cal. App. 4th 712 (2014), as modified on denial of reh’g (Apr. 3, 2014),
 review denied (June 11, 2014); State v. Ortega, 749 N.W.2d 851 (Minn. Ct. App. 2008),
 aff’d, 770 N.W.2d 145 (Minn. 2009); People v. Zuniga, 372 P.3d 1052 (Colo. 2016).
 Upon careful consideration, in agreement with the conclusions of the Court of
 Special Appeals and the appellate courts of other jurisdictions, we hold that a law
 enforcement officer has probable cause to search a vehicle where the law enforcement
 officer detects an odor of marijuana emanating from the vehicle, as marijuana in any
 amount remains contraband, notwithstanding the decriminalization of possession of less
 than ten grams of marijuana; and the odor of marijuana gives rise to probable cause to
 believe that the vehicle contains contraband or evidence of a crime. Simply put,
 decriminalization is not synonymous with legalization, and possession of marijuana
 remains unlawful.
 BACKGROUND
 No. 37: Robinson v. State
 On October 19, 2014, in the District Court of Maryland, sitting in Baltimore City,
 the State, Respondent, charged Robinson with possession of oxycodone, possession of at
 least ten grams of marijuana, and possession of drug paraphernalia. The case was
 transferred to the Circuit Court for Baltimore City. In the circuit court, Robinson filed
 “Omnibus Pre-Trial Defense Motions,” which included, among other things, a motion to
 suppress all evidence that law enforcement had allegedly illegally seized from Robinson’s
 vehicle.
 On March 16, 2015, the circuit court conducted a hearing on the motion to suppress.
 -4-
 The only witness at the hearing was Officer Steven A. Vinias of the Baltimore Police
 Department. As a witness for the State, Officer Vinias testified that he was familiar with
 the odor of marijuana, and was able to distinguish the odor of fresh marijuana from the
 odor of burnt marijuana. On October 18, 2014, Officer Vinias was driving in the 3100
 block of Oakfield Avenue in Baltimore. Sergeant Luis Ruiz was a passenger in the law
 enforcement vehicle. Officer Vinias saw Robinson leaning against a Nissan Maxima,
 which was the only vehicle on that side of Oakfield Avenue. Officer Vinias noticed an
 overwhelming smell of fresh marijuana. Officer Vinias stopped, and he and Sergeant Ruiz
 exited and approached Robinson, who was within arm’s length of the Nissan at the time.
 Robinson made a movement toward his waistband, and Sergeant Ruiz detained Robinson.
 Once Robinson was detained, Officer Vinias could tell that the smell of marijuana was
 coming from the Nissan. In response to questions by Officer Vinias, Robinson said that he
 had been driving the Nissan, and that there was marijuana in the Nissan. Officer Vinias
 searched the Nissan and seized sixteen small bags of marijuana and one oxycodone pill.
 At the time of the seizure, Officer Vinias estimated that the marijuana weighed more than
 ten grams. On cross-examination, Officer Vinias stated that the strength of the odor of
 marijuana and the amount of marijuana are not always synonymous.
 After Officer Vinias’s testimony, the circuit court heard argument from the parties.
 Robinson’s counsel contended that a law enforcement officer lacks probable cause to
 search a vehicle for marijuana unless the law enforcement officer has reasonable suspicion
 that the vehicle contains more than ten grams of marijuana. The State argued that nothing
 had changed as a result of the amendment to the marijuana statute with respect to a law
 -5-
 enforcement officer’s ability to search a vehicle based on the odor of marijuana. After
 hearing the parties’ arguments, the circuit court denied the motion to suppress without
 making any findings of fact.
 The parties agreed that Robinson would be tried on an agreed statement of facts only
 as to the charge of possession of at least ten grams of marijuana. Robinson’s counsel
 engaged in a waiver colloquy with Robinson, who waived the right to a trial. The
 prosecutor read a statement of facts, to which Robinson’s counsel agreed. The circuit court
 found Robinson guilty of possession of at least ten grams of marijuana and sentenced him
 to time served. The docket entries reflect that the other two charges, possession of
 oxycodone and possession of drug paraphernalia, were closed.
 On March 26, 2015, Robinson noted an appeal. In an unreported opinion dated
 April 29, 2016, the Court of Special Appeals affirmed the circuit court’s judgment, holding
 that, despite the decriminalization of possession of less than ten grams of marijuana,
 marijuana remains contraband, and its odor provides probable cause to search a vehicle.
 On June 14, 2016, Robinson petitioned for a writ of certiorari, raising the following
 two issues:
 1. When an officer detects an “overwhelming smell” of “fresh marijuana”
 coming from a car, does he have probable cause to search the car in light of
 the fact that possession of a less than ten grams of marijuana is now a “civil
 offense” punishable only by a fine?
 2. Did the trial court err when it denied [] Robinson’s motion to suppress?
 On August 19, 2016, this Court granted the petition. See Robinson v. State, 449 Md. 410,
 144 A.3d 705 (2016).
 -6-
 No. 39: Williams v. State
 On April 8, 2015, in the District Court of Maryland, sitting in Baltimore City, the
 State charged Williams with possession of marijuana and possession of drug paraphernalia.
 The case was transferred to the Circuit Court for Baltimore City. In the circuit court,
 Williams filed “Omnibus Pre-Trial Defense Motions,” which included, among other
 things, a motion to suppress all evidence that law enforcement had allegedly illegally
 seized from Williams’s vehicle.
 On June 25, 2015, the circuit court conducted a hearing on the motion to suppress.
 The only witness at the hearing was Detective Tristan Ferguson of the Baltimore Police
 Department. As a witness for the State, Detective Ferguson testified that he was familiar
 with the odor of marijuana, and was able to distinguish the odor of fresh marijuana from
 the odor of burnt marijuana. According to Detective Ferguson, the greater the amount of
 fresh marijuana, the stronger the odor and the greater the radius in which the marijuana can
 be smelled. On April 8, 2015, Detective Ferguson was driving in the 4500 block of
 Fairview Avenue in Baltimore. Detective Ferguson saw Williams in the driver’s seat of a
 vehicle that was stopped in front of a stop sign. Detective Ferguson exited the law
 enforcement vehicle and approached Williams. Once he was within four feet of Williams’s
 vehicle, Detective Ferguson smelled a strong odor of fresh marijuana emanating from
 Williams’s vehicle. Detective Ferguson asked Williams whether he smoked marijuana,
 and Williams replied affirmatively. Detective Ferguson asked Williams to exit his vehicle.
 Detective Ferguson searched Williams’s vehicle and seized a backpack that contained a
 canister, which contained a scale and 170 grams of packaged marijuana. On cross-
 -7-
 examination, Detective Ferguson acknowledged that even a small amount of the most
 powerful grade of marijuana, known as “loud,” would have a potent odor.
 Following Detective Ferguson’s testimony, the circuit court heard argument from
 the parties. Williams’s counsel contended that probable cause to believe that a person is
 engaged in conduct that constitutes a civil violation of the law—e.g., possession of less
 than ten grams of marijuana—does not provide a basis for a warrantless search. The State
 argued that the General Assembly had specifically indicated that decriminalization of
 possession of less than ten grams of marijuana would not affect law enforcement officers’
 authority to seize marijuana. After hearing the parties’ arguments, the circuit court denied
 the motion to suppress.
 On June 25, 2015, after the circuit court denied the motion to suppress, Williams
 pled guilty to possession of at least ten grams of marijuana. The prosecutor read a
 statement of facts, to which Williams’s counsel agreed. The circuit court found Williams
 guilty of possession of at least ten grams of marijuana and postponed sentencing.
 On July 2, 2015, Williams filed a “Motion for New Trial,” requesting a new trial
 and that he be permitted to enter a conditional guilty plea, and thus preserve the right to
 appeal the denial of the motion to suppress. Docket entries reflect that, on July 21, 2015,
 a verdict of guilty was entered as to the charge for possession of at least ten grams of
 marijuana; the charge for possession of drug paraphernalia was closed; and the circuit court
 sentenced Williams to twenty days of incarceration.
 On August 5, 2015, Williams noted an appeal. In an unreported opinion dated May
 18, 2016, the Court of Special Appeals affirmed the circuit court’s judgment, holding that
 -8-
 the odor of marijuana alone provides probable cause to search a vehicle.
 On June 27, 2016, Williams petitioned for a writ of certiorari, raising the following
 two issues:
 1. When an officer smells “the odor of marijuana strongly emanating from
 the interior” of a car and when the driver and sole occupant admits that he
 has an unspecified amount of marijuana in the car, does the officer have
 probable cause to search the car in light of the fact that possession of a less
 than ten grams of marijuana is now a “civil offense” punishable only by a
 fine?
 2. Did the trial court err when it denied [] Williams’[s] motion to suppress?
 On September 2, 2016, this Court granted the petition. See Williams v. State, 450 Md.
 104, 146 A.3d 464 (Sept. 2, 2016).
 No. 46: Spriggs v. State
 On December 11, 2014, in the Circuit Court for Dorchester County, the State
 charged Spriggs with possession of cocaine with the intent to distribute, possession of
 marijuana with the intent to distribute, possession of cocaine, possession of marijuana, and
 two counts of possession of drug paraphernalia. In the circuit court, Spriggs filed an
 “Omnibus Motion for Appropriate Relief Under Rule 4-252,” which included, among other
 things, a motion to suppress all evidence that law enforcement had allegedly illegally
 seized.
 On April 20, 2015, the circuit court conducted a hearing on the motion to suppress.
 Two witnesses testified at the hearing. As a witness for the State, Corporal Jeffrey Smith
 of the Cambridge Police Department testified that he was familiar with the odor of fresh
 marijuana. According to Corporal Smith, the greater the amount of marijuana, the stronger
 -9-
 the odor. On October 18, 2014, Corporal Smith was driving down Elm Street in Cambridge
 with the windows down and detected a strong odor of fresh marijuana. Corporal Smith
 saw Spriggs in a vehicle in a parking lot in front of an abandoned building. Corporal Smith
 observed that the front passenger-side door was open, and Spriggs was sitting in the
 passenger’s seat with his feet outside the vehicle. The odor of marijuana weakened as
 Corporal Smith drove further down Elm Street. Corporal Smith made a U-turn, parked the
 law enforcement vehicle, exited, and approached Spriggs. While Corporal Smith
 approached, Spriggs exited his vehicle and began walking toward the back of his vehicle.
 Meanwhile, Corporal Robert Ball drove down Elm Street, parked his law enforcement
 vehicle, exited, and reached Spriggs before Corporal Smith did. While Corporal Ball was
 speaking with Spriggs, Corporal Smith walked away from Spriggs’s vehicle, and noticed
 that the odor of marijuana weakened. Corporal Smith walked back toward Spriggs’s
 vehicle; at that point, Corporal Smith believed that he could tell that the odor of marijuana
 was coming from the general area of Spriggs’s vehicle. At that time, Spriggs was holding
 keys in his left hand; and, other than Corporals Smith and Ball, no one was in Spriggs’s
 general area.
 As a witness for the State, Corporal Ball testified that the greater the amount of
 marijuana, the stronger the odor. Corporal Ball testified that, on October 18, 2014, he
 drove down Elm Street and saw Corporal Smith on foot. Corporal Ball parked his law
 enforcement vehicle, exited, and approached Spriggs, who was near a parked Honda Civic.
 The Honda was the only vehicle in the parking lot. As he approached Spriggs, Corporal
 Ball smelled a strong odor of fresh marijuana. Corporal Ball asked Spriggs how he was
 - 10 -
 doing and whether he was just hanging out in the area. Spriggs said yes. Corporal Ball
 testified that Corporal Smith said that he smelled marijuana. Spriggs said that he smelled
 marijuana too, and that a couple of other people had just left the area. Corporal Ball
 testified that no one else was in the area, and that he smelled marijuana coming from
 Spriggs’s person. Spriggs was asked who owned the Honda, and Spriggs said that his boss
 did. Corporal Ball testified that Spriggs told him that “he [Spriggs] had the vehicle” and
 that he had been the only one in the Honda. Corporal Ball searched Spriggs and found a
 large amount of United States currency, but no marijuana. Corporal Ball asked Spriggs for
 the Honda’s key, and Spriggs complied. Corporal Ball searched the Honda.3
 After Corporal Ball’s testimony, the circuit court heard argument from the parties.
 Spriggs’s counsel contended that the odor of marijuana alone cannot justify a warrantless
 search. The State contended that, based on prior case law, law enforcement officers have
 the right to investigate upon detecting the odor of marijuana. After hearing the parties’
 arguments, the circuit court denied the motion to suppress, making findings of fact that
 were consistent with Corporal Smith’s testimony and Corporal Ball’s testimony.
 On April 29, 2015, Spriggs elected a bench trial, at which Corporal Smith and
 Corporal Ball testified as witnesses for the State. As witness for the State, Detective
 Edward Howard of the Cambridge Police Department testified that, when he was part of
 the Narcotics Division, he delivered the bags of suspected drugs taken from the Honda to
 3
 At trial, Corporal Smith testified that he found marijuana in a Ziploc bag in a plastic
 grocery bag in front of the Honda’s driver’s seat, and that he found cocaine in another
 Ziploc bag in the Honda.
 - 11 -
 a crime lab in Berlin. As a witness for the State, Detective Jamie McDaniel testified that
 the seized items were $3,056 in United States currency, 143 grams of cocaine, and 142
 grams of marijuana.
 The circuit court found Spriggs guilty of possession of cocaine with the intent to
 distribute, possession of marijuana with the intent to distribute, possession of cocaine, and
 possession of marijuana. The circuit court found Spriggs not guilty of both counts of
 possession of drug paraphernalia. The circuit court sentenced Spriggs to twenty years of
 imprisonment, with all but three years suspended, for possession of cocaine with the intent
 to distribute; five consecutive years of imprisonment, with all but one year and one day
 suspended, for possession of marijuana with the intent to distribute; and five years of
 supervised probation. The circuit court merged the remaining two convictions for
 sentencing purposes.
 On May 6, 2015, Spriggs noted an appeal. In an unreported opinion dated June 23,
 2016, the Court of Special Appeals affirmed the circuit court’s judgment, concluding that
 the odor of marijuana alone provides probable cause to search a vehicle.
 On August 3, 2016, Spriggs petitioned for a writ of certiorari, raising the following
 two issues:
 1. When an officer detects an “overwhelming strong odor” of “raw
 marijuana” coming from a car, does he have probable cause to search the car
 in light of the fact that possession of less than ten grams of marijuana is now
 a “civil offense” punishable only by a fine?
 2. Did the trial court err when it denied [] Spriggs’s motion to suppress?
 On September 2, 2016, this Court granted the petition. See Spriggs v. State, 450 Md. 102,
 - 12 -
 146 A.3d 463 (Sept. 2, 2016).
 DISCUSSION
 The Parties’ Contentions
 Petitioners contend that, because the General Assembly has made possession of less
 than ten grams of marijuana a civil offense that is punishable by a fine, a law enforcement
 officer may not conduct a warrantless search of a vehicle based only on the odor of
 marijuana. Petitioners argue that the odor of marijuana alone does not constitute probable
 cause that a vehicle contains more than ten grams of marijuana because the odor of
 marijuana indicates only its presence, not its amount. Petitioners assert that law
 enforcement officers could not conduct warrantless searches of their vehicles because a
 search warrant cannot be issued for civil offenses. Petitioners point out that a warrantless
 search is permissible only where reasonable. Petitioners maintain that Carroll v. United
 States, 267 U.S. 132 (1925) and its progeny do not answer the question of whether it is
 reasonable for a law enforcement officer to search for items, the possession of which is not
 criminal. Petitioners contend that whether a search is reasonable does not depend on the
 General Assembly’s intent in decriminalizing possession of a small amount of marijuana.
 Alternatively, Petitioners argue that, if relevant, the General Assembly’s intent was to limit
 the enforcement of laws related to the possession of marijuana, including laws related to
 searches.
 The State responds that the decriminalization of possession of less than ten grams
 of marijuana does not affect existing case law that permits a warrantless search of a vehicle
 based on the odor of marijuana. The State contends that the Carroll doctrine permits the
 - 13 -
 warrantless search of a vehicle based on probable cause to believe that the vehicle contains
 contraband or evidence of a crime. The State asserts that “contraband” and “evidence of a
 crime” are not synonymous, as “contraband” includes anything that is unlawful to possess,
 regardless of whether possession is criminal. The State maintains that, despite the
 decriminalization of possession of less than ten grams of marijuana, marijuana remains
 contraband, which is subject to seizure, and that the odor of marijuana coming from a
 vehicle gives rise to probable cause to believe evidence of a crime may be found in the
 vehicle. The State points out that courts in other jurisdictions have applied the Carroll
 doctrine and upheld warrantless searches based on the odor of marijuana. In sum, the State
 argues that the odor of marijuana provides probable cause to believe that a vehicle contains
 contraband or evidence of a crime.
 The Standard of Review
 In Varriale v. State, 444 Md. 400, 410, 119 A.3d 824, 830 (2015), this Court
 explained the standard of review for a ruling on a motion to suppress as follows:
 In reviewing a trial court’s ruling on a motion to suppress, an appellate court
 reviews for clear error the trial court’s findings of fact, and reviews without
 deference the trial court’s application of the law to its findings of fact. The
 appellate court views the trial court’s findings of fact, the evidence, and the
 inferences that may be drawn therefrom in the light most favorable to the
 party who prevails on the issue that the defendant raises in the motion to
 suppress.
 (Citation omitted).
 The Fourth Amendment, the Carroll Doctrine, and Contraband
 The Fourth Amendment to the United States Constitution provides in pertinent part:
 “The right of the people to be secure in their persons, houses, papers, and effects, against
 - 14 -
 unreasonable searches and seizures, shall not be violated[.]” U.S. Const. amend. IV.4 The
 Fourth Amendment does not prohibit all searches—only unreasonable ones. See Sellman
 v. State, 449 Md. 526, 540, 144 A.3d 771, 779 (2016). Whether a search is reasonable
 depends on the public interest versus an individual’s right to be free from arbitrary
 interference by a law enforcement officer. See id. at 540, 144 A.3d at 779.
 Generally, for a search to be reasonable, a law enforcement officer must obtain a
 warrant. See Riley v. California, ___ U.S. ___, 134 S. Ct. 2473, 2482 (2014). One
 exception to the warrant requirement is the “automobile exception,” under which a law
 enforcement officer may conduct a warrantless search of a vehicle based on probable cause.
 See California v. Acevedo, 500 U.S. 565, 569 (1991). The automobile exception originates
 from the case of Carroll, 267 U.S. 132, and has been referred to as “the Carroll doctrine.”
 See Acevedo, 500 U.S. at 569-70. In Wyoming v. Houghton, 526 U.S. 295, 300 (1999),
 the Supreme Court discussed Carroll as follows:
 Carroll . . . involved the warrantless search of a car that law enforcement
 officials had probable cause to believe contained contraband—in that case,
 bootleg liquor. The Court concluded that the Framers would have regarded
 such a search as reasonable in light of legislation enacted by Congress from
 1789 through 1799—as well as subsequent legislation from the founding era
 and beyond—that empowered customs officials to search any ship or vessel
 without a warrant if they had probable cause to believe that it contained
 goods subject to a duty. Thus, the Court held that “contraband goods
 concealed and illegally transported in an automobile or other vehicle may be
 searched for without a warrant” where probable cause exists.
 (Citations omitted).
 4
 The Fourth Amendment applies to the States under the Due Process Clause of the
 Fourteenth Amendment to the United States Constitution. See Sellman v. State, 449 Md.
 526, 539, 144 A.3d 771, 779 (2016).
 - 15 -
 Probable cause exists where, based on the available facts, a person of reasonable
 caution would believe “that contraband or evidence of a crime is present.” Florida v.
 Harris, ___ U.S. ___, 133 S. Ct. 1050, 1055 (2013) (emphasis added) (citations omitted).
 Probable cause does not depend on a preponderance of the evidence, but instead depends
 on a “fair probability” on which a reasonably prudent person would act. Id. (citation
 omitted). Specifically, in Illinois v. Gates, 462 U.S. 213, 231 (1983), the Supreme Court
 described the concept of probable cause as follows:
 [T]he probable cause standard is . . . a “practical, nontechnical conception.”
 “In dealing with probable cause, as the very name implies, we deal with
 probabilities. These are not technical; they are the factual and practical
 considerations of everyday life on which reasonable and prudent [people],
 not legal technicians, act.” Our observation in United States v. Cortez, 449
 U.S. 411, 418, 101 S. Ct. 690, 695, 66 L. Ed. 2d 621 (1981), regarding
 “particularized suspicion,” is also applicable to the probable cause standard:
 The process does not deal with hard certainties, but with
 probabilities. Long before the law of probabilities was
 articulated as such, practical people formulated certain
 common-sense conclusions about human behavior; jurors as
 factfinders are permitted to do the same—and so are law
 enforcement officers. Finally, the evidence thus collected must
 be seen and weighed not in terms of library analysis by
 scholars, but as understood by those versed in the field of law
 enforcement.
 As these comments illustrate, probable cause is a fluid concept—turning on
 the assessment of probabilities in particular factual contexts—not readily, or
 even usefully, reduced to a neat set of legal rules.
 (Ellipsis and some citations omitted). And more recently, in Harris, 133 S. Ct. at 1055-
 56, the Supreme Court stated:
 The test for probable cause is not reducible to precise definition or
 quantification. Finely tuned standards such as proof beyond a reasonable
 doubt or by a preponderance of the evidence have no place in the probable-
 - 16 -
 cause decision. All we have required is the kind of fair probability on which
 reasonable and prudent people, not legal technicians, act.
 In evaluating whether the State has met this practical and common-
 sensical standard, we have consistently looked to the totality of the
 circumstances. We have rejected rigid rules, bright-line tests, and
 mechanistic inquiries in favor of a more flexible, all-things-considered
 approach. . . .
 (Citations, ellipsis, brackets, and internal quotation marks omitted).
 As to the automobile exception to the warrant requirement, in Carroll, 267 U.S. at
 153, the Supreme Court held that, with probable cause to believe that a vehicle contains
 contraband, a law enforcement officer may search a vehicle without a warrant, because
 vehicles can be quickly moved from one jurisdiction to another, thus making it
 impracticable to obtain a warrant. In Carroll, during the Prohibition era, a law enforcement
 officer stopped a vehicle, searched the vehicle, and found alcohol inside of the vehicle. See
 Carroll, 267 U.S. at 172 (McReynolds, J., dissenting).5 The occupants of the vehicle were
 found guilty of violating a statute that made it a crime to transport alcohol in violation of
 the National Prohibition Act. See Carroll, 267 U.S. at 144-45. On appeal, the defendants
 argued that a law enforcement officer could conduct a warrantless search of a vehicle only
 if the law enforcement officer could arrest the driver—which the law enforcement officer
 could do only if he or she either had probable cause to believe that the driver had committed
 a felony, or had seen the driver commit a misdemeanor. See id. at 156-57. The Supreme
 Court rejected the defendants’ contention, concluding that a law enforcement officer’s
 5
 Justice McReynolds’s dissenting opinion expounded on Carroll’s facts in greater
 detail than the majority opinion did. Compare Carroll, 267 U.S. at 160-61 with id. at 171-
 74 (McReynolds, J., dissenting).
 - 17 -
 ability to search a vehicle does not depend on the law enforcement officer’s right to make
 an arrest, but instead depends on probable cause to believe that the vehicle’s contents are
 illegal. See id. at 158-59. Specifically, the Court stated: “The right to search and the
 validity of the seizure are not dependent on the right to arrest. They are dependent on the
 reasonable cause the seizing officer has for belief that the contents of the automobile offend
 against the law.” Id. Although the Court noted that, under the National Prohibition Act,
 the driver of a vehicle that contained alcohol was subject to arrest, the Court determined
 that the nature of the offense for which the driver could be prosecuted did not affect the
 validity of the search. See id. at 159. In sum, in Carroll, id. at 153, 158-59, the Supreme
 Court concluded that, with probable cause to believe that a vehicle contains contraband, a
 law enforcement officer may search a vehicle without a warrant, and the determination of
 probable cause does not depend upon the right to make an arrest.
 Following Carroll, the Supreme Court has stated that a law enforcement officer has
 probable cause to search a vehicle when he or she believes that contraband or evidence of
 a crime may be found in the vehicle. For example, in Harris, 133 S. Ct. at 1053, 1055, a
 case involving a drug-detection dog’s alert during a traffic stop, the Supreme Court stated:
 “A police officer has probable cause to conduct a search when the facts available to him
 [or her] would warrant a person of reasonable caution in the belief that contraband or
 evidence of a crime is present.” (Citation, brackets, and internal quotation marks omitted).
 In Houghton, 526 U.S. at 297, 304, a case involving a search of a passenger’s personal
 belongings inside of an automobile, the Supreme Court stated:
 Effective law enforcement would be appreciably impaired without the ability
 - 18 -
 to search a passenger’s personal belongings when there is reason to believe
 contraband or evidence of criminal wrongdoing is hidden in the car. As in
 all car-search cases, the ‘ready mobility’ of an automobile creates a risk that
 the evidence or contraband will be permanently lost while a warrant is
 obtained.
 (Citation omitted). And, in Texas v. Brown, 460 U.S. 730, 733, 742 (1983), a case
 involving a routine driver’s license checkpoint stop, the Supreme Court stated:
 As the Court frequently has remarked, probable cause is a flexible,
 common-sense standard. It merely requires that the facts available to the
 officer would warrant a [person] of reasonable caution in the belief, that
 certain items may be contraband or stolen property or useful as evidence of
 a crime; it does not demand any showing that such a belief be correct or more
 likely true than false.
 (Citation and internal quotation marks omitted).
 The Decriminalization of Possession of Less Than Ten Grams of Marijuana
 Before October 1, 2014, Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2013
 Supp.) § 5-601 was effective, and stated in relevant part:
 (a) Except as otherwise provided in this title, a person may not:
 (1) possess or administer to another a controlled dangerous substance,
 unless obtained directly or by prescription or order from an authorized
 provider acting in the course of professional practice;
 ***
 (c) (1) Except as provided in paragraphs (2) and (3) of this subsection, a
 person who violates this section is guilty of a misdemeanor and on conviction
 is subject to imprisonment not exceeding 4 years or a fine not exceeding
 $25,000 or both.
 (2) (i) A person whose violation of this section involves the use or
 possession of marijuana is subject to imprisonment not exceeding 1
 year or a fine not exceeding $1,000 or both.
 (ii) 1. A person convicted of the use or possession of less
 - 19 -
 than 10 grams of marijuana is subject to imprisonment not exceeding
 90 days or a fine not exceeding $500 or both.
 2014 Md. Laws. 1119, 1124 (Vol. II, Ch. 158, S.B. 364). Thus, before 2014, possession
 of marijuana in any amount was a crime—albeit one that carried less of a maximum penalty
 than possession of other drugs.
 In 2014, the General Assembly amended Md. Code Ann., Crim. Law (2002, 2012
 Repl. Vol., 2013 Supp.) § 5-601(c)(2), the penalty provisions regarding marijuana, to state
 in pertinent part:
 (i) Except as provided in subparagraph (ii) of this paragraph, a person whose
 violation of this section involves the use or possession of marijuana is subject
 to imprisonment not exceeding 1 year or a fine not exceeding $1,000 or both.
 (ii) 1. A first violation of this section involving the use or possession of
 less than 10 grams of marijuana is a civil offense punishable by a fine not
 exceeding $100.
 2. a second violation of this section involving the use or possession of
 less than 10 grams of marijuana is a civil offense punishable by a fine not
 exceeding $250.
 3. a third or subsequent violation of this section involving the use or
 possession of less than 10 grams of marijuana is a civil offense punishable
 by a fine not exceeding $500.
 4. A. In addition to a fine, a court shall order a person under the
 age of 21 years who commits a violation punishable under
 subsubparagraph 1, 2, or 3 of this subparagraph to attend a drug
 education program approved by the Department of Health and Mental
 Hygiene, refer the person to an assessment for substance abuse
 disorder, and refer the person to substance abuse treatment, if
 necessary.
 B. In addition to a fine, a court shall order a person at least 21
 years old who commits a violation punishable under subsubparagraph
 3 of this subparagraph to attend a drug education program approved
 by the Department of Health and Mental Hygiene, refer the person to
 - 20 -
 an assessment for substance abuse disorder, and refer the person to
 substance abuse treatment, if necessary.
 2014 Md. Laws. 1119 (Vol. II, Ch. 158, S.B. 364).6
 6
 Although the General Assembly has amended the statute since 2014, the penalty
 provisions regarding marijuana remain substantively identical; and, subsubparagraph
 (ii)(4)(C) has been added. Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2016 Supp.)
 § 5-601(c)(2) currently states:
 (i) Except as provided in subparagraph (ii) of this paragraph, a person whose
 violation of this section involves the use or possession of marijuana in the
 amount of 10 grams or more is guilty of the misdemeanor of possession of
 marijuana and is subject to imprisonment not exceeding 1 year or a fine not
 exceeding $1,000 or both.
 (ii) 1. A first finding of guilt under this section involving the use or
 possession of less than 10 grams of marijuana is a civil offense punishable
 by a fine not exceeding $100.
 2. A second finding of guilt under this section involving the use or
 possession of less than 10 grams of marijuana is a civil offense punishable
 by a fine not exceeding $250.
 3. A third or subsequent finding of guilt under this section involving
 the use or possession of less than 10 grams of marijuana is a civil offense
 punishable by a fine not exceeding $500.
 4. A. In addition to a fine, a court shall order a person under the
 age of 21 years who commits a violation punishable under
 subsubparagraph 1, 2, or 3 of this subparagraph to attend a drug
 education program approved by the Department of Health and Mental
 Hygiene, refer the person to an assessment for substance abuse
 disorder, and refer the person to substance abuse treatment, if
 necessary.
 B. In addition to a fine, a court shall order a person at least 21
 years old who commits a violation punishable under subsubparagraph
 3 of this subparagraph to attend a drug education program approved
 by the Department of Health and Mental Hygiene, refer the person to
 an assessment for substance abuse disorder, and refer the person to
 - 21 -
 The General Assembly also added Md. Code Ann., Crim. Law (2002, 2012 Repl.
 Vol., 2014 Supp.) § 5-601(d), which stated:
 The provisions of subsection (c)(2)(ii) of this section making the possession
 of marijuana a civil offense may not be construed to affect the laws relating
 to:
 (1) operating a vehicle or vessel while under the influence of or while
 impaired by a controlled dangerous substance; or
 (2) seizure and forfeiture.
 2014 Md. Laws. 1122 (Vol. II, Ch. 158, S.B. 364).
 Additionally, the General Assembly created Md. Code Ann., Crim. Law (2002,
 2012 Repl. Vol., 2014 Supp.) § 5-601.1, which stated in pertinent part:
 (a) A police officer shall issue a citation to a person who the police officer
 has probable cause to believe has committed a violation of § 5-601 of this
 part involving the use or possession of less than 10 grams of marijuana.
 (b) (1) A violation of § 5-601 of this part involving the use or possession
 of less than 10 grams of marijuana is a civil offense.
 (2) Adjudication of a violation under § 5-601 of this part involving
 the use or possession of less than 10 grams of marijuana:
 (i) is not a criminal conviction for any purpose; and
 (ii) does not impose any of the civil disabilities that may result
 from a criminal conviction.
 2014 Md. Laws. 1122-23 (Vol. II, Ch. 158, S.B. 364).
 substance abuse treatment, if necessary.
 C. A court that orders a person to a drug education program or
 substance abuse assessment or treatment under this subsubparagraph
 may hold the case sub curia pending receipt of proof of completion of
 the program, assessment, or treatment.
 - 22 -
 Bowling v. State
 Although this Court has not yet addressed the impact of the decriminalization of
 possession of less than ten grams of marijuana on an analysis of probable cause, the Court
 of Special Appeals has done so. In Bowling, 227 Md. App. at 476, 134 A.3d at 398, the
 Court of Special Appeals concluded that the decriminalization of possession of less than
 ten grams of marijuana did not alter the status of marijuana as contraband in Maryland, and
 that a narcotics dog’s alert provides probable cause to search a vehicle pursuant to the
 Carroll doctrine. In Bowling, 227 Md. App. at 462, 134 A.3d at 390, a law enforcement
 officer stopped a vehicle that the defendant was driving. The law enforcement officer
 noticed that the defendant appeared nervous, and the officer called for a narcotics dog. See
 id. at 462-63, 134 A.3d at 390. Before the narcotics dog arrived, the defendant exited his
 vehicle, and was unable to get back in because he had locked his key inside. See id. at 463,
 134 A.3d at 390. The narcotics dog arrived, and alerted near the rear driver’s side door.
 See id. at 463-64, 134 A.3d at 390-91. Afterward, a tow truck driver arrived, and opened
 the defendant’s vehicle. See id. at 464, 134 A.3d at 391. The law enforcement officer,
 who had been planning to have the defendant’s vehicle towed to the police station,
 immediately searched the defendant’s vehicle instead of conducting an inventory search at
 the police station. See id. at 464, 134 A.3d at 391. The law enforcement officer found
 nearly 200 grams of marijuana, an OxyContin tablet, a smoking device, a scale, and a large
 amount of cash. See id. at 464, 134 A.3d at 391. The defendant moved to suppress all of
 the evidence that had been found in his vehicle, contending that the narcotics dog’s alert
 did not provide probable cause for a warrantless search of the vehicle in light of the General
 - 23 -
 Assembly’s decriminalization of possession of less than ten grams of marijuana, and
 because the narcotics dog could not distinguish between more than ten grams of marijuana
 and less than ten grams of marijuana. See id. at 464-65, 134 A.3d at 391.
 The trial court denied the motion to suppress, and the Court of Special Appeals
 affirmed the trial court’s judgment. See id. at 465, 476,134 A.3d at 391, 398. The Court
 of Special Appeals explained that decriminalization is not synonymous with legalization;
 even though possession of less than ten grams of marijuana is no longer a crime, it is still
 illegal. See id. at 470, 134 A.3d at 394. The Court of Special Appeals examined the plain
 meaning and legislative history of the statute decriminalizing possession of less than ten
 grams of marijuana and concluded: “[I]t is clear that the [] General Assembly intended that
 marijuana remain classified as ‘contraband,’ and that the decriminalization of small
 amounts of marijuana would not affect existing case law allowing officers to search a
 vehicle based upon a K-9 alert to the smell of marijuana.” Id. at 476, 134 A.3d at 398. The
 Court of Special Appeals also examined case law from the Supreme Court and other
 jurisdictions and concluded that the automobile exception to the warrant requirement is not
 limited to where there is probable cause to believe there is evidence of a crime in a vehicle;
 rather, the Court of Special Appeals determined that “a search is permitted when there is
 probable cause to believe that the car contains evidence of a crime or contraband.” Id. at
 472, 134 A.3d at 396 (emphasis in original). The Court of Special Appeals explained that
 marijuana in any amount remains contraband—i.e., goods that are unlawful to possess. See
 id. at 476, 134 A.3d at 398. As such, in Bowling, id. at 476, 134 A.3d at 398, the narcotics
 dog’s alert provided probable cause to believe that contraband would be discovered in the
 - 24 -
 vehicle irrespective of the decriminalization of possession of less than ten grams of
 marijuana.7
 Other Jurisdictions’ Case Law
 Courts in other jurisdictions have addressed whether decriminalization—or, in one
 instance, legalization—of possession of a small amount of marijuana negates probable
 cause to search a vehicle based on an odor of marijuana. The view of the majority of other
 jurisdictions that have addressed the issue—four out of five jurisdictions, to be exact—is
 that decriminalization has no such effect. A sixth jurisdiction has determined that
 legalization of possession of a small amount of marijuana does not foreclose the existence
 of probable cause to search a vehicle upon detection of an odor of marijuana.
 In Barclay, 398 A.2d at 798, the Supreme Judicial Court of Maine held that, despite
 a statute that made possession of a small amount of marijuana “a civil violation,” marijuana
 remained contraband, and thus remained subject to seizure. In Barclay, id. at 796, a law
 enforcement officer stopped a vehicle that the defendant was driving because the vehicle’s
 exhaust system appeared to be faulty. While at the driver’s side of the vehicle, the law
 enforcement officer smelled marijuana smoke. See id. The law enforcement officer
 7
 The Court of Special Appeals’s holding in Bowling is consistent with prior case
 law in which the Court of Special Appeals and this Court have held that a drug detection
 dog’s alert provides probable cause for the search of a vehicle. See McKoy v. State, 127
 Md. App. 89, 101, 732 A.2d 312, 318 (1999) (The Court of Special Appeals held that a law
 enforcement officer did not unreasonably detain the defendant by conducting a traffic stop
 during which a narcotics dog scanned a vehicle.); Wilkes v. State, 364 Md. 554, 565, 586,
 774 A.2d 420, 426, 439 (2001) (This Court held that law enforcement officers had probable
 cause to search the defendant’s vehicle and the defendant where a narcotics dog,
 accompanied by a licensed trained handler, alerted to the presence of drugs in the
 defendant’s vehicle.).
 - 25 -
 searched the vehicle and found two pipes and several marijuana cigarette butts, which were
 tested and found to contain marijuana. See id. The defendant moved to suppress the
 marijuana, contending that the search was illegal because the Fourth Amendment does not
 permit a search for evidence of a civil violation. See id.
 A trial court denied the motion to suppress, and the Supreme Judicial Court of Maine
 affirmed. See id. at 796, 798. In Barclay, id. at 797, the Court concluded that the law
 enforcement officer “had probable cause to believe that the vehicle in question contained
 marijuana. When [the officer] arrived at the driver’s window, he detected the odor of
 marijuana smoke emanating from the interior of the vehicle. That odor was sufficient to
 establish probable cause to search.” The Court determined that a law enforcement officer
 may search for goods whose possession is punishable only by a civil violation, as such
 goods can be the subject of a search warrant under Maine statutes. See id. at 797-98. The
 Court specifically stated that “marijuana, notwithstanding its new status under [a Maine
 statute], is still contraband and thus subject to seizure.” Id. at 798.
 In Smalley, 225 P.3d at 848, the Court of Appeals of Oregon determined that,
 notwithstanding a statute that made possession of less than an ounce of marijuana a civil
 violation, marijuana in any amount still constituted contraband. In Smalley, id. at 845, a
 law enforcement officer stopped a vehicle in which the defendant was a passenger. The
 driver consented to a search of the vehicle, and the law enforcement officer noticed an odor
 of marijuana coming from a backpack behind the driver’s seat. See id. The law
 enforcement officer searched the backpack and discovered marijuana, and the defendant
 admitted that the backpack belonged to him. See id. The defendant moved to suppress the
 - 26 -
 marijuana, contending that the search violated the Oregon Constitution’s counterpart to the
 Fourth Amendment. See id.
 A trial court granted the motion to suppress, and the Court of Appeals of Oregon
 reversed. See id. at 845, 848. The Court concluded that the law enforcement officer had
 probable cause to believe that the backpack contained “at least some amount of
 contraband” based on the officer’s testimony concerning the odor of marijuana emanating
 from the backpack. See id. at 847. The defendant contended that a law enforcement officer
 cannot search for marijuana without probable cause to believe that there is a criminal
 amount of marijuana. See id. at 848. The Court rejected this contention and concluded
 that a law enforcement officer may conduct a warrantless search for “contraband or crime
 evidence” where there is probable cause to believe that such items are in a container in a
 vehicle. Id. at 848 (citation and emphasis omitted). The Court explained that the phrase
 “contraband or crime evidence” indicated that the two were not identical, and “that
 probable cause to believe in the presence of either could justify an automobile search.” Id.
 (citation omitted). Thus, the Court determined that a law enforcement officer could search
 for goods that were contraband, even if the goods did not constitute evidence of a crime.
 See id. The Court observed that, under both its legal definition and its common definition,
 “contraband” includes anything that is illegal to possess—which encompasses marijuana
 in any amount. See id.
 In Waxler, 224 Cal. App. 4th at 715, a Court of Appeal of California held that,
 despite a statute under which possession of less than an ounce of marijuana was punishable
 only by a fine, a law enforcement officer has probable cause to search a vehicle where the
 - 27 -
 law enforcement officer smells burnt marijuana emanating from the vehicle and sees burnt
 marijuana in a pipe in the vehicle.8 In Waxler, id. at 716, a law enforcement officer
 approached a parked vehicle in which the defendant was sitting in the driver’s seat. As the
 law enforcement officer got closer to the vehicle, he noticed an odor of burnt marijuana
 and saw a marijuana pipe that contained what appeared to be burnt marijuana. See id. The
 law enforcement officer searched the vehicle and found methamphetamine and a
 methamphetamine pipe. See id. The defendant moved to suppress, contending that the
 law enforcement officer lacked probable cause to believe that the defendant had been
 committing a crime. See id. at 717.
 A trial court denied the motion to suppress, and the Court of Appeal of California
 affirmed. See id. at 716. The Court noted that, despite the removal of incarceration as a
 possible penalty for possession of less than an ounce of marijuana, marijuana in any amount
 remained illegal, and thus still constituted contraband. See id. at 721. The Court stated
 that its holding was not limited to situations where a law enforcement officer sees or smells
 more than an ounce of marijuana; instead, a law enforcement officer has probable cause to
 search a vehicle where the law enforcement officer detects marijuana in any amount. See
 id. at 725. Specifically, the Court concluded that the law enforcement officer “had probable
 cause to believe [the defendant]’s truck contained contraband after smelling burnt
 marijuana near the truck and seeing burnt marijuana in the truck, irrespective of whether
 possession of up to an ounce of marijuana is an infraction and not an arrestable offense.”
 8
 In 2016, after the Court of Appeal of California’s decision in Waxler, California
 legalized possession of a small amount of marijuana. See supra note 1.
 - 28 -
 Id. at 721 (citation omitted). The Court noted that other jurisdictions had reached similar
 conclusions. See id.
 In Ortega, 749 N.W.2d at 853-54, the Court of Appeals of Minnesota held that the
 odor of marijuana provides probable cause to search a vehicle, notwithstanding a statute
 under which possession of a small amount of marijuana was not a crime. In Ortega, id. at
 852, a law enforcement officer stopped a vehicle in which the defendant was a passenger.
 The law enforcement officer noticed an odor of burnt marijuana coming from the vehicle’s
 passenger compartment. See id. The driver consented to a search of the vehicle, and the
 law enforcement officer asked the defendant to exit the vehicle. See id. The law
 enforcement officer patted down the defendant, who handed over a pocket knife and a
 small amount of marijuana. See id. A narcotics dog alerted to the vehicle’s center console
 and the seat where the defendant had been sitting. See id. The law enforcement officer
 searched the vehicle’s center console and found a rolled-up dollar bill with cocaine on it.
 See id. at 852-53. The law enforcement officer searched the defendant more thoroughly
 and found a folded dollar bill with cocaine on it. See id. at 853. The defendant moved to
 suppress the cocaine. See id. at 853.
 A trial court denied the motion to suppress, and the Court of Appeals of Minnesota
 affirmed. See id. at 852. The Court concluded that the law enforcement officer had
 probable cause to search the vehicle based on the odor of marijuana. See id. at 854. The
 Court also determined that the law enforcement officer had probable cause to search the
 defendant after he handed over a noncriminal amount of marijuana because, whether
 detected by sight or smell, the presence of marijuana in any amount in one location
 - 29 -
 indicates that there may be more in another location. See id. Specifically, the Court held
 that the law enforcement officer had probable cause to search the defendant “for a
 criminally significant quantity of marijuana upon smelling the odor of marijuana emanating
 from within the vehicle,” and that the officer “had an independent basis for probable cause
 when [the defendant] later also handed [the officer] the small, noncriminal amount of
 marijuana from his pocket.” Id.
 In Zuniga, 372 P.3d at 1060, the Supreme Court of Colorado held that a law
 enforcement officer had probable cause to search a vehicle where, among other
 circumstances, the law enforcement officer smelled an odor of marijuana. In Zuniga, id.
 at 1054, the law enforcement officer stopped a vehicle in which the defendant was a
 passenger. As he approached the passenger-side window, the law enforcement officer
 noticed a strong odor of fresh marijuana. See id. The law enforcement officer spoke with
 the defendant and the driver, who exhibited extreme nervousness and provided inconsistent
 information. See id. at 1055. A law enforcement officer had a narcotics dog scan the
 vehicle, and the narcotics dog alerted to the vehicle’s rear hatch, which contained a duffel
 bag. See id. The law enforcement opened the duffel bag and found marijuana inside. See
 id. The law enforcement officer then opened a cooler that had been next to the duffel bag,
 and found more marijuana inside. See id. The defendant admitted that the marijuana in
 both containers was his. See id. The defendant moved to suppress the marijuana, and a
 trial court granted the motion to suppress, determining that the law enforcement officer
 lacked probable cause to search the vehicle. See id.
 The government appealed, and the Supreme Court of Colorado reversed. See id. at
 - 30 -
 1056, 1060. The Court determined that the trial court erred in disregarding the odor of
 marijuana in its analysis of probable cause; the Court explained that, even though
 possession of up to an ounce of marijuana is legal under Colorado law, several other
 marijuana-related activities remained unlawful. See id. at 1059-60. Specifically, the Court
 stated: “[T]he odor of marijuana remains relevant to probable cause determinations and
 can support an inference that a crime is ongoing even though possession of one ounce or
 less of marijuana is allowed under Colorado law.” Id. at 1060. Accordingly, the Court
 concluded that an odor of marijuana suggests criminal activity, and remains relevant to an
 analysis of probable cause. See id.
 By contrast, in Commonwealth v. Overmyer, 11 N.E.3d 1054, 1060 (Mass. 2014),
 the Supreme Judicial Court of Massachusetts concluded that the odor of fresh marijuana
 did not give rise to probable cause to search a vehicle. In Overmyer, id. at 1055-56, law
 enforcement officers responded to a vehicle collision in which the defendant’s vehicle had
 rear-ended another vehicle. The law enforcement officers noticed a strong odor of fresh
 marijuana near the defendant’s vehicle. See id. at 1056. One of the law enforcement
 officers asked the defendant whether his vehicle contained marijuana, and the defendant
 responded in the affirmative and provided the key to his vehicle’s glove compartment. See
 id. One of the law enforcement officers found a bag of marijuana in the defendant’s
 vehicle’s glove compartment. See id. After removing the bag of marijuana, the law
 enforcement officers continued to detect a strong odor of marijuana in the defendant’s
 vehicle. See id. One of the law enforcement officers questioned the defendant, who
 eventually admitted that his vehicle contained more marijuana. See id. One of the law
 - 31 -
 enforcement officers found a backpack in the defendant’s vehicle’s backseat; the backpack
 contained more marijuana. See id. The defendant moved to suppress all of the marijuana
 found in his vehicle. See id. at 1057. A trial court denied the motion to suppress as to the
 bag that was in the defendant’s vehicle’s glove compartment, but granted the motion to
 suppress as to the marijuana that was in the backpack. See id. The State appealed, and,
 while Overmyer was pending in the intermediate appellate court, the Supreme Judicial
 Court of Massachusetts transferred the case on its own initiative. See id.
 The Court vacated the trial court’s grant of the motion to suppress, and remanded
 with instructions to determine whether the law enforcement officers had probable cause to
 arrest the defendant after they seized the marijuana in the glove compartment. See id. at
 1060. The Court noted that, in an earlier case, Commonwealth v. Cruz, 945 N.E.2d 899,
 910 (Mass. 2011), the Court had held that, because Massachusetts’s legislature had made
 possession of one ounce or less of marijuana “a civil violation,” the odor of burnt marijuana
 alone did not suggest criminal activity. See Overmyer, 11 N.E.3d at 1058. Addressing the
 circumstance of fresh marijuana in Overmyer, id., the Court reasoned that, although the
 strength of the odor of fresh marijuana could correlate to the amount of marijuana more
 closely than the strength of the odor of burnt marijuana, it did not follow that a strong odor
 of fresh marijuana indicated a criminal amount, which was necessary to establish probable
 cause. The Court observed that the record contained “no evidence that the officers [] had
 undergone specialized training that, if effective, would allow them reliably to discern, by
 odor, not only the presence and identity of a controlled substance, but also its weight.” Id.
 at 1059. The Court opined:
 - 32 -
 In sum, we are not confident, at least on this record, that a human nose can
 discern reliably the presence of a criminal amount of marijuana, as distinct
 from an amount subject only to a civil fine. In the absence of reliability, a
 neutral magistrate would not issue a search warrant, and therefore a
 warrantless search is not justified based solely on the smell of marijuana,
 whether burnt or unburnt.
 Id. at 1059-60 (citations and internal quotation marks omitted).
 Analysis
 Upon careful consideration of the Fourth Amendment jurisprudence of the Supreme
 Court, Bowling, and authority from other jurisdictions that have addressed the
 decriminalization—or, in one instance, the legalization—of marijuana, we conclude that a
 law enforcement officer has probable cause to search a vehicle where the law enforcement
 officer detects an odor of marijuana emanating from the vehicle.
 Our logic is straightforward. Decriminalization is not the same as legalization.
 Despite the decriminalization of possession of less than ten grams of marijuana, possession
 of marijuana in any amount remains illegal in Maryland. To be sure, the amended
 marijuana statute changed the categorization of, and maximum penalty for, possession of
 less than ten grams of marijuana. Specifically, possession of less than ten grams of
 marijuana is now categorized as a civil offense rather than a crime, and it is punishable by
 a fine, participation in a drug education program, an assessment for substance abuse
 disorder, and possible substance abuse treatment, rather than a fine and/or a period of
 incarceration. Decriminalization notwithstanding, however, the possession of less than ten
 grams of marijuana—i.e., the possession of any amount of marijuana—remains illegal. See
 Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2016 Supp.) § 5-601(c).
 - 33 -
 Petitioners contend that the General Assembly’s intent in decriminalizing
 possession of less than ten grams of marijuana is irrelevant to the issue of whether probable
 cause exists to search a vehicle based on the odor of marijuana. Although not dispositive
 of whether a law enforcement officer may search a vehicle upon detection of the odor of
 marijuana, we observe that the relevant statutes’ plain language and legislative history
 support the conclusion that the General Assembly did not intend to preclude a search of a
 vehicle based on the odor of marijuana. In changing the classification of possession of less
 than ten grams of marijuana from a “misdemeanor” to “a civil offense,” the General
 Assembly made clear that possession of marijuana in any amount is still illegal. See 2014
 Md. Laws. 1119 (Vol. II, Ch. 158, S.B. 364). Significantly, when decriminalizing
 possession of less than ten grams of marijuana, the General Assembly added Md. Code
 Ann., Crim. Law (2002, 2012 Repl. Vol., 2014 Supp.) § 5-601(d)(2), which states that the
 decriminalization “may not be construed to affect the laws relating to . . . seizure and
 forfeiture.” See 2014 Md. Laws. 1122 (Vol. II, Ch. 158, S.B. 364) (paragraph break
 omitted). As to laws relating to seizure, since 2002, Md. Code Ann., Crim. Proc. (2001,
 2002 Supp.) § 12-201(a)(1) has stated: “A Schedule I substance listed in § 5-402 of the
 Criminal Law Article shall be seized and summarily forfeited to the State if the substance
 is[] possessed, transferred, sold, or offered for sale in violation of the Controlled Dangerous
 Substances law[.]” (Paragraph break omitted). Marijuana is, and has been, a Schedule I
 substance subject to seizure and forfeiture. See Md. Code Ann., Crim. Law (2002, 2012
 Repl. Vol.) § 5-402(d)(1)(vii).
 In other words, the plain language of the relevant statutes demonstrate that the
 - 34 -
 General Assembly expressly indicated that decriminalization of possession of less than ten
 grams of marijuana does not mean that law enforcement officers can no longer seize
 marijuana. Indeed, Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2014 Supp.) § 5-
 601(d)(2) plainly provides that the provisions “making the possession of marijuana a civil
 offense may not be construed to affect the laws relating to . . . seizure and forfeiture.”
 (Paragraph break omitted). Thus, under the plain language of the statutes, marijuana
 remains a Schedule I substance that is subject to seizure and forfeiture, notwithstanding the
 circumstance that possession of less than ten grams of marijuana is now a civil offense. By
 definition, if law enforcement officers may still seize marijuana, then law enforcement
 officers may still search for marijuana.
 The legislative history of the amended statute also makes clear that the General
 Assembly did not intend to preclude a search of a vehicle based on the odor of marijuana
 or to otherwise alter the seizure and forfeiture of marijuana. As the Court of Special
 Appeals has observed with respect to the statute’s legislative history:
 On April 1, 2014, at the hearing to discuss Senate Bill 364, members of the
 House Judiciary Committee questioned whether this bill, as initially drafted,
 would cause a change in the existing law authorizing police officers to search
 a car based on a K-9 alert. Senator Robert Zirkin, one of the sponsors of the
 bill, testified that this was not a problem in most states that had
 decriminalized small amounts of marijuana, but he stated that, if the General
 Assembly wanted to make that clear, it could amend the bill.
 On April 5, 2014, the House Judiciary Committee adopted an
 amendment to address this issue. This amendment added the [] language
 regarding seizure and forfeiture, which ultimately was codified at [Md. Code
 Ann., Crim. Law (2002, 2012 Repl. Vol., 2014 Supp.)] § 5-601(d)[.]
 ...
 - 35 -
 In light of the foregoing, it is clear that the [] General Assembly
 intended that marijuana remain classified as “contraband,” and that the
 decriminalization of small amounts of marijuana would not affect existing
 case law allowing officers to search a vehicle based upon a K-9 alert to the
 smell of marijuana.
 Bowling, 227 Md. App. at 474-75, 134 A.3d at 397 (citations omitted). In addition to the
 testimony referenced in Bowling, at the same hearing, Senator Zirkin testified that “[t]he
 intention of this bill is not to stop what would be right now a lawful search incident to
 arrest.” See Crim. L. Possession of Marijuana Civ. Offense: Hearing on S.B. 364 Before
 the Sen. Jud. Comm., 2014 Reg. Sess. (Md. Apr. 1, 2014). Senator Zirkin clarified that
 “[t]his is not legalization.” Id. The legislative history, and the enactment of Md. Code
 Ann., Crim. Law (2002, 2012 Repl. Vol., 2014 Supp.) § 5-601(d), make clear that the
 decriminalization of possession of small amounts of marijuana was not to affect existing
 case law allowing law enforcement officers to search a vehicle based not only upon a K-9
 alert to the smell of marijuana, but also based upon a law enforcement officer’s own
 detection of the smell of marijuana. In short, the statute’s plain language and legislative
 history demonstrate that the General Assembly, in decriminalizing possession of small
 amounts of marijuana, did not intend to otherwise alter existing case law concerning the
 search, seizure, and forfeiture of marijuana, which remains illegal.
 Aside from the statute’s plain language and legislative history, in our independent
 assessment of the issue, we conclude that a warrantless search of a vehicle is permissible
 upon detection of the odor of marijuana emanating from the vehicle. For purposes of the
 Fourth Amendment, probable cause to search exists where a person of reasonable caution
 would believe “that contraband or evidence of a crime is present.” Harris, 133 S. Ct. at
 - 36 -
 1055 (citations omitted); see also Houghton, 526 U.S. at 304 (“contraband or evidence of
 criminal wrongdoing”); Brown, 460 U.S. at 742 (“contraband or stolen property or useful
 as evidence of a crime”). The Supreme Court’s use of the phrase “contraband or evidence
 of a crime” demonstrates that the terms “contraband” and “evidence of a crime” have
 different meanings. In our view, “contraband” means goods that are illegal to possess,
 regardless of whether possession of the goods is a crime. The definition of “contraband”
 that we adopt is warranted by the Supreme Court’s conclusion in Carroll, 267 U.S. at 158-
 59, that a law enforcement officer can search a vehicle based on probable cause to believe
 that the vehicle’s contents are contraband, even if the law enforcement officer cannot arrest
 the driver.
 The conclusion that the terms “contraband” and “evidence of a crime” are not
 synonymous is supported by the plain meaning of the word “contraband.” Significantly,
 the words “crime” and “criminal” do not appear in the definitions of “contraband” in both
 Black’s Law Dictionary and Merriam-Webster. Black’s Law Dictionary defines
 contraband, in relevant part, as “[g]oods that are unlawful to import, export, produce, or
 possess.” Contraband, Black’s Law Dictionary (10th ed. 2014) (emphasis added).
 Similarly, Merriam-Webster defines contraband, in relevant part, as “goods or merchandise
 whose importation, exportation, or possession is forbidden[.]” Contraband, Merriam-
 Webster, http://www.merriam-webster.com/dictionary/contraband [https://perma.cc/
 PDL8-V83L] (emphasis added). These definitions support the conclusion that marijuana
 in any amount constitutes contraband. Moreover, if “contraband” and “evidence of a
 crime” had the same meaning, then it would have been superfluous for the Supreme Court
 - 37 -
 to have included “contraband” in its explanation of probable cause.
 We recognize that Petitioners argue that the contraband in Carroll, namely, the
 prohibited alcohol, was a crime to possess, and that the term “contraband” refers to items
 that are criminal to possess. The fallacy of this argument is that, in Carroll, the Supreme
 Court concluded that ability to search does not depend on the suspected offense being an
 offense for which arrest is authorized. Petitioners rely on Warden, Md. Penitentiary v.
 Hayden, 387 U.S. 294, 296 (1967) for the proposition that the Supreme Court considered
 the term “contraband,” and concluded that, in the context of the Fourth Amendment, items
 that may be searched for include “the instrumentalities and means by which a crime is
 committed, the fruits of crime such as stolen property, weapons by which escape of the
 person arrested might be effected, and property the possession of which is a crime.”
 (Footnote and internal quotation marks omitted). This reliance is misplaced. We observe
 that in Hayden, the Supreme Court sought to describe items that may be seized pursuant to
 the execution of a search and seizure warrant of a home after a determination of probable
 cause has been made. Accordingly, in Hayden, id. at 307, the Supreme Court determined
 that there must be a nexus between the items to be seized and the criminal behavior at issue,
 i.e., the criminal behavior that necessitated the need for the warrant. With its holding in
 Hayden, the Supreme Court sought to define the permissible scope for the seizure of items
 from a home upon the execution of a search warrant, and thereby to ensure that seizures in
 such circumstances would not be unnecessarily broad or intrusive. This is vastly different
 from describing whether a law enforcement officer has probable cause to conduct a
 warrantless search of a vehicle based on the belief the vehicle contains contraband or
 - 38 -
 evidence of a crime. The suggestion that the definition of “contraband” for purpose of the
 warrantless search of an automobile is limited to “property the possession of which is a
 crime” appears nowhere in the Supreme Court’s decision in Hayden.
 We note that, in each of the three instant cases, the first question presented in the
 petition for a writ of certiorari referred to the circumstance that, according to law
 enforcement testimony, the odor of marijuana was either strong (in Williams and Spriggs)
 or overwhelming (in Robinson). Rather than cabining our holding to the requirement that
 the odor must be strong or overwhelming, we conclude that the odor of marijuana provides
 probable cause to search a vehicle. As discussed above, marijuana in any amount, no
 matter how small, is contraband; accordingly, the odor of marijuana constitutes probable
 cause to search a vehicle. In other words, for purposes of probable cause, there is no
 distinction between the significance of a criminal amount of marijuana versus the
 significance of a noncriminal—but still illegal—amount of marijuana. As the parties
 acknowledge, it is effectively impossible for law enforcement officers to identify a quantity
 of marijuana based on odor alone. Indeed, according to the law enforcement officers’
 testimony in the instant cases, the strength of the odor of marijuana and the amount of
 marijuana do not always correlate, and even a small amount of the most powerful grade of
 marijuana may have a strong odor. Thus, requiring that law enforcement officers detect a
 strong or overwhelming odor of marijuana to have probable cause to conduct a warrantless
 search a vehicle would serve no useful purpose.
 We join the Court of Special Appeals and courts in other jurisdictions in holding
 that marijuana remains contraband, despite the decriminalization of possession of small
 - 39 -
 amounts of marijuana, and that, as such, the odor of marijuana constitutes probable cause
 for the search of a vehicle. In Bowling, 227 Md. App. at 476, 134 A.3d at 398, the Court
 of Special Appeals held that, notwithstanding the decriminalization of possession of less
 than ten grams of marijuana in Maryland, a narcotics dog’s alert provides probable cause
 to search a vehicle. In Barclay, 398 A.2d at 798, the Supreme Judicial Court of Maine held
 that marijuana was contraband even though a Maine statute made possession of a small
 amount of marijuana “a civil violation.” In Smalley, 225 P.3d at 848, the Court of Appeals
 of Oregon held that marijuana in any amount is contraband, despite an Oregon statute under
 which possession of less than an ounce of marijuana is a civil violation. And, in Waxler,
 224 Cal. App. 4th at 715, a Court of Appeal of California held that a law enforcement
 officer has probable cause to search a vehicle where the law enforcement officer smells
 burnt marijuana and sees burnt marijuana in a pipe in the vehicle, notwithstanding a
 California statute that made possession of less than an ounce of marijuana punishable only
 by a fine. In Ortega, 749 N.W.2d at 853-54, the Court of Appeals of Minnesota concluded
 that the odor of marijuana gave rise to probable cause to search a vehicle, even though
 possession of a small amount of marijuana was not a crime in the state. And, in Zuniga,
 372 P.3d at 1060, the Supreme Court of Colorado determined that there was probable cause
 to search a vehicle where, among other things, a law enforcement officer detected the odor
 of marijuana, even though possession of up to one ounce of marijuana is legal in Colorado.
 At oral argument, Petitioners’ counsel contended that Barclay, Smalley, Waxler,
 Ortega, and Zuniga are unpersuasive because the cases allegedly involve a mechanical
 application of the term “contraband,” and the respective appellate courts did not analyze
 - 40 -
 whether the Carroll doctrine applies to items that are not criminal, but rather are illegal, to
 possess. We disagree. Although the appellate courts in other jurisdictions did not
 explicitly mention the Carroll doctrine by name, each court determined that probable cause
 existed to search a vehicle based on the odor of marijuana where the State had
 decriminalized—or, in one instance, legalized—possession of marijuana. In Barclay,
 Smalley, and Waxler, the appellate courts specifically determined that marijuana was
 contraband notwithstanding its decriminalization; it was still illegal to possess marijuana.
 In those three cases, the appellate courts applied the principle that a law enforcement officer
 may conduct a warrantless search of a vehicle where the law enforcement officer has
 probable cause to believe that the vehicle contains contraband, and the appellate courts
 came to the conclusion that a noncriminal amount of marijuana remains contraband. See
 Barclay, 398 A.2d at 798; Smalley, 225 P.3d at 848; Waxler, 224 Cal. App. 4th at 720. In
 Ortega, 749 N.W.2d at 853-54, and Zuniga, 372 P.3d at 1060, the appellate courts reached
 similar conclusions. This is entirely consistent with the Supreme Court’s holding in
 Carroll, 267 U.S. at 158-59, that the existence of probable cause to search a vehicle does
 not depend on the ability to arrest.9
 9
 We note that, in Bowling, 227 Md. App. at 470, 134 A.3d at 394, the Court of
 Special Appeals distinguished the case of State v. Crocker, 97 P.3d 93 (Alaska Ct. App.
 2004), on which the defendant in Bowling relied, explaining:
 In Crocker, the Court of Appeals of Alaska held that the “strong odor of
 growing marijuana” did not constitute probable cause to support a search
 warrant for Crocker’s house because, in Alaska, it is legal to possess less than
 four ounces of marijuana for personal use in the home. [97 P.3d] at 95, 97.
 The court held that the warrant application needed to establish probable cause
 - 41 -
 We decline to follow Overmyer, 11 N.E.3d at 1057-58, in which the Supreme
 Judicial Court of Massachusetts held that an odor of marijuana does not provide probable
 cause to search a vehicle; in so holding, the Court equated “contraband” with criminal
 goods. We decline to adopt the Court’s reasoning, as we do not see a basis for determining
 the existence of criminal contraband as opposed to other types of contraband. As discussed
 above, the term “contraband” includes more than items or goods that are criminal to
 possess, but may also include items or goods that are simply illegal to possess.
 Overmyer has the effect of precluding all warrantless searches of vehicles based on
 the odor of marijuana, which would not be a salutary development in Maryland. The
 Supreme Judicial Court of Massachusetts theorized that it may be possible for a law
 enforcement officer to be trained to gauge the amount of marijuana based on odor alone,
 but based its holding on the circumstance that the record did not demonstrate that a law
 enforcement officer could discern a criminal amount of marijuana. See Overmyer, 11
 N.E.3d at 1059. It is unclear, however, whether the training to which that Court referred
 would ever be possible at all, let alone effective. Thus, were we to adopt the rationale of
 Overmyer, unless law enforcement officers were trained to detect by odor alone the
 that the possession of marijuana was illegal. Id. at 94. That case is inapposite
 because, as explained, possession of marijuana in any amount remains illegal
 in Maryland.
 We observe that, in addition to possession of marijuana in any amount remaining illegal in
 Maryland as opposed to the circumstance in Alaska where statutes provided that adults
 may possess any amount less than four ounces of marijuana in the home for personal use,
 Crocker, 97 P.3d at 94, is further distinguishable because it involved execution of a search
 warrant of a home, and not a warrantless search of a vehicle.
 - 42 -
 difference between less than ten grams of marijuana and ten grams or more of marijuana,
 law enforcement officers would not be able to conduct warrantless searches of vehicles
 based on the odor of marijuana. This would permit a myriad of crimes to go undetected.
 Indeed, at oral argument and in its brief, the State argued that, separate from the
 odor of marijuana providing probable cause to believe that a vehicle contains contraband,
 the odor of marijuana provides probable cause to believe that a vehicle contains evidence
 of a crime. Put simply, we agree. Despite the decriminalization of possession of less than
 ten grams of marijuana, the odor of marijuana remains evidence of a crime. The odor of
 marijuana emanating from a vehicle may be just as indicative of crimes such as the
 possession of more than ten grams of marijuana, possession of marijuana with the intent to
 distribute, or the operation of a vehicle under the influence of a controlled dangerous
 substance, as it is of possession of less than ten grams of marijuana. As explained above,
 it is unreasonable to expect law enforcement officers to determine, based on odor alone,
 the difference between 9.99 grams or less of marijuana and 10 grams of marijuana. In
 short, possession of ten grams or more of marijuana, crimes involving the distribution of
 marijuana, and driving under the influence of a controlled dangerous substance have not
 been decriminalized in Maryland, and, thus, the odor of marijuana emanating from a
 vehicle provides probable cause to believe that the vehicle contains evidence of a crime,
 and a law enforcement officer may search the vehicle under such circumstances.
 We find no merit in the contention that it is unreasonable to permit law enforcement
 officers to conduct a warrantless search of a vehicle based on the odor of marijuana.
 Petitioners argue that Carroll and its progeny do not answer the question of whether it is
 - 43 -
 reasonable to permit law enforcement officers to search for noncriminal items, and that
 warrantless searches should not be permitted where officers could not obtain a search
 warrant. In Maryland, marijuana, in any amount, is a Schedule I substance. See Md. Code
 Ann., Crim. Law (2002, 2012 Repl. Vol.) § 5-402(d)(1)(vii). By statute, all Schedule I
 substances are subject to seizure and summary forfeiture “to the State if the substance[] is
 possessed, transferred, sold, or offered for sale in violation of the Controlled Dangerous
 Substances [L]aw[.]” Md. Code Ann., Crim. Proc. (2001, 2002 Supp.) § 12-201(a)(1)
 (paragraph break omitted). Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2014
 Supp.) § 5-601(c)(2)(ii), which makes possession of less than ten grams of marijuana a
 civil offense, is part of the Controlled Dangerous Substances Law. And Md. Code Ann.,
 Crim. Law (2002, 2012 Repl. Vol., 2014 Supp.) § 5-601(d)(2) provides that the provisions
 “making the possession of marijuana a civil offense may not be construed to affect the laws
 relating to . . . seizure and forfeiture.” (Paragraph break omitted). Because marijuana, in
 any amount, is subject to seizure and forfeiture, it can be the legitimate object of a search
 warrant, notwithstanding the circumstance that possession of less than ten grams of
 marijuana is a civil offense. Indeed, Md. Code Ann., Crim. Proc. (2001, 2008 Repl. Vol.,
 2014 Supp.) § 1-203(a)(1)(ii) provides that “[a] circuit court judge or District Court judge
 may issue forthwith a search warrant whenever it is made to appear to the judge, by
 application . . . , that there is probable cause to believe that[] property subject to seizure
 under the criminal laws of the State is on the person or in or on the building, apartment,
 premises, place, or thing.” (Paragraph break omitted). The seizure of Schedule I
 substances is authorized under the criminal laws of the State of Maryland, and nothing in
 - 44 -
 Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2014 Supp.) § 5-601 purported to alter
 the classification of marijuana as a Schedule I substance. Because marijuana is property
 subject to seizure under the criminal laws of the State, a search warrant may be obtained.
 We observe that our holding in the instant cases does not in any way impede the
 ability of eligible persons to possess and/or use marijuana for medical purposes. Under
 Md. Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2016 Supp.) § 5-601(c)(3)(iii)1, in a
 prosecution for possession or use of marijuana, a defendant may raise as an affirmative
 defense the circumstances that “the defendant has a debilitating medical condition that has
 been diagnosed by a physician with whom the defendant has a bona fide physician-patient
 relationship”; “the debilitating medical condition is severe and resistant to conventional
 medicine”; and “marijuana is likely to provide the defendant with therapeutic or palliative
 relief from the debilitating medical condition.” (Paragraph breaks omitted). Under Md.
 Code Ann., Crim. Law (2002, 2012 Repl. Vol., 2016 Supp.) § 5-601(c)(3)(iii)2A, in a
 prosecution for possession of marijuana, a defendant may raise as an affirmative defense
 the circumstance that “the marijuana was intended for medical use by an individual with a
 debilitating medical condition for whom the defendant is a caregiver.” Md. Code Ann.,
 Crim. Law (2002, 2012 Repl. Vol., 2016 Supp.) § 5-601(c)(3)(iii)3A and B provide that a
 defendant may not raise an affirmative defense if the defendant was either “using marijuana
 in a public place or assisting the individual for whom the defendant is a caregiver in using
 the marijuana in a public place” or “in possession of more than 1 ounce of marijuana.”
 Code of Maryland Regulations (“COMAR”) 10.62.04.02 and 10.62.04.04 require
 medical marijuana patients and caregivers, respectively, to apply for registration with the
 - 45 -
 Natalie M. LaPrade Maryland Medical Cannabis Commission (“the Cannabis
 Commission”).10 COMAR 10.62.06.01 and 10.62.06.02 enable medical marijuana patients
 and caregivers, respectively, to apply for Cannabis Commission-issued identification cards
 that include the registration numbers that the Cannabis Commission has assigned to the
 medical marijuana patients and caregivers.
 Further, Md. Code Ann., Health-Gen. (1982, 2015 Repl. Vol.) § 13-3313(a)
 provides, in pertinent part, as follows:
 Any of the following persons acting in accordance with the provisions of this
 subtitle may not be subject to arrest, prosecution, or any civil or
 administrative penalty, including a civil penalty or disciplinary action by a
 professional licensing board, or be denied any right or privilege, for the
 medical use of cannabis:
 (1) A qualifying patient:
 (i) In possession of an amount of medical cannabis determined
 by the [Cannabis] Commission to constitute a 30-day supply; or
 (ii) In possession of an amount of medical cannabis that is
 greater than a 30-day supply if the qualifying patient’s certifying
 physician stated in the written certification that a 30-day supply would
 be inadequate to meet the medical needs of the qualifying patient;
 ...
 (4) A caregiver[.11]
 10
 In 2013, the General Assembly authorized the Cannabis Commission, which was
 originally entitled the Natalie M. LaPrade Medical Marijuana Commission. See 2013 Md.
 Laws 3625 (Vol. IV, Ch. 403, H.B. 1101). The General Assembly directed that the
 Cannabis Commission would be independent, but would function within the Department
 of Health and Mental Hygiene. See id. at 3623. In 2015, the General Assembly gave the
 Cannabis Commission its current name. See 2015 Md. Laws 1164 (Vol. II, Ch. 251, H.B.
 490).
 11
 The Cannabis Commission’s website advises medical marijuana patients that, if a
 law enforcement officer stops them, they do not have to disclose that they possess
 marijuana, and do not have to consent to a search; however, if a law enforcement officer
 - 46 -
 Permitting law enforcement officers to conduct a warrantless search of a vehicle based on
 the odor of marijuana will have no effect upon the statutes and regulations pertaining to
 medical marijuana.
 Conclusion
 For the reasons set forth above, we hold that a law enforcement officer has probable
 cause to search a vehicle where the law enforcement officer detects an odor of marijuana
 emanating from the vehicle, as marijuana in any amount remains contraband,
 notwithstanding the decriminalization of possession of less than ten grams of marijuana;
 and the odor of marijuana gives rise to probable cause to believe that the vehicle contains
 contraband or evidence of a crime. Applying our holding to the instant cases, we conclude
 that there was probable cause to search the vehicles in question, based on a law enforcement
 officer having detected an odor of marijuana coming from a vehicle that Petitioner had
 been driving or in possession of. Accordingly, we affirm the judgments of the Court of
 Special Appeals.
 IN CASE NO. 37, JUDGMENT OF THE COURT
 OF SPECIAL APPEALS AFFIRMED.
 PETITIONER TO PAY COSTS.
 IN CASE NO. 39, JUDGMENT OF THE COURT
 OF SPECIAL APPEALS AFFIRMED.
 PETITIONER TO PAY COSTS.
 conducts a search and finds marijuana, a medical marijuana patient should offer his or her
 Cannabis Commission-issued identification card and direct the law enforcement officer to
 the Cannabis Commission’s database. See Patients FAQ’s, Natalie M. LaPrade Maryland
 Medical Cannabis Commission (updated Dec. 7, 2016), http://mmcc.maryland.gov/pages/
 patients/patients_faq.aspx [https://perma.cc/P8XH-T7XB].
 - 47 -
 IN CASE NO. 46, JUDGMENT OF THE COURT
 OF SPECIAL APPEALS AFFIRMED.
 PETITIONER TO PAY COSTS.
 - 48 -


type: caselaw

jurisdiction: EU

text:
 1.8.2009
 CS
 Úřední věstník Evropské unie
 C 180/11
 Rozsudek Soudního dvora (třetího senátu) ze dne 18. června 2009 (žádost o rozhodnutí o předběžné otázce Hoge Raad der Nederlanden Den Haag — Nizozemsko) — Staatssecretaris van Financiën v. Stadeco BV
 (Věc C-566/07) (1)
 („Šestá směrnice o DPH - Článek 21 odst. 1 písm. c) - Daň dlužná pouze z důvodu jejího uvedení na faktuře - Oprava bezdůvodně naúčtované daně - Bezdůvodné obohacení“)
 2009/C 180/17
 Jednací jazyk: nizozemština
 Předkládající soud
 Hoge Raad der Nederlanden Den Haag
 Účastníci původního řízení
 Žalobce: Staatssecretaris van Financiën
 Žalovaná: Stadeco BV
 Předmět věci
 Žádost o rozhodnutí o předběžné otázce — Hoge Raad der Nederlanden Den Haag — Výklad čl. 21 odst. 1 písm. c) směrnice 77/388/EHS: Šestá směrnice Rady ze dne 17. května 1997 o harmonizaci právních předpisů členských států týkajících se daní z obratu — Společný systém daně z přidané hodnoty: jednotný základ daně (Úř. věst. L 145, s. 1) — Neexistence povinnosti zaplatit daň v členském státě sídla vystavitele faktury za plnění uskutečněné v jiném členském státě nebo ve třetí zemi — Oprava neodůvodněně vyúčtované daně
 Výrok
 1)
 Článek 21 odst. 1 písm. c) šesté směrnice Rady 77/388/EHS ze dne 17. května 1977 o harmonizaci právních předpisů členských států týkajících se daní z přidané hodnoty — Společný systém daně z přidané hodnoty: jednotný základ daně, ve znění směrnice Rady 91/680/EHS ze dne 16. prosince 1991, musí být vykládán v tom smyslu, že podle tohoto ustanovení existuje povinnost odvést daň z přidané hodnoty v tom členském státě, ke kterému se vztahuje daň z přidané hodnoty uvedená na faktuře nebo jiném dokladu sloužícím jako faktura, i když dotčené plnění nebylo v tomto členském státu předmětem daně. Předkládajícímu soudu přísluší, aby s přihlédnutím ke všem relevantním okolnostem ověřil, ke kterému členskému státu se daň z přidané hodnoty uvedená na dotčené faktuře vztahuje. V tomto ohledu mohou být relevantní zejména sazba uvedené daně, měna, ve které je vyjádřena dlužná částka, jazyk vyhotovení, obsah a kontext dotčené faktury, místo, ve kterém jsou vystavitel této faktury a příjemce poskytnuté služby usazeni, jakož i jejich chování.
 2)
 V případě, že osoba povinná k dani včas zcela nevyloučila nebezpečí ztráty daňových příjmů, nebrání zásada daňové neutrality v zásadě tomu, aby členský stát podmínil opravu daně z přidané hodnoty, která je v daném členském státě dlužná pouze z důvodu jejího nesprávného uvedení na odeslané faktuře, tím, že osoba povinná k dani příjemci poskytnutých služeb dodatečně zašle opravenou fakturu, na které není tato daň uvedena.
 (1) Úř. věst. C 64, 8.3.2008.