People v. Williams, 990 N.E.2d 916

Vehicle stopped for speeding; odor of cannabis detected from interior during stop; Williams was a front-seat passenger; driver Cook claimed vehicle belonged to cousin; defendant was searched after shoes were removed; 43 grams of cannabis found on defendant; other items (pink pills, stun gun) found in vehicle; motion to suppress denied; issue on appeal was whether odor from vehicle justifies warrantless search of passenger.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does odor of cannabis from a vehicle provide probable cause to search a passenger?	People argue odor implicates all occupants; scent creates probable cause to search each person.	Williams contends odor does not automatically justify searching him as a passenger.	Yes; odor provides probable cause to search the passenger.
Is the search justified under vehicle-occupant search doctrine given probable cause to search the vehicle?	Prosecution asserts vehicle probable cause extends to occupants; passenger may be searched when odor localizes to the vehicle.	Defense argues Di Re limits extending vehicle search to passengers absent individualized intrusion.	Search of the passenger permissible under vehicle-occupant doctrine with odor localization.

Di Re v. United States, 332 U.S. 581 (1948) (probable cause to search vehicle does not automatically include passenger)
Houghton v. Wyoming, 526 U.S. 295 (1999) (purse search permissible when vehicle search probable-cause-related)
People v. Stout, 106 Ill.2d 77 (1985) (odor of cannabis can establish probable cause with training; totality of circumstances)
People v. Boyd, 298 Ill.App.3d 1118 (1998) (odor of burning cannabis can support search of occupants)
Coolidge v. New Hampshire, 403 U.S. 443 (1971) (exigent circumstances justify warrantless automobile searches on roadway)
Florida v. Harris, 133 S. Ct. 1050 (2013) (probable cause is a fluid probability standard; reliable odor localization supports search)