According to United States v. White, what is insufficient to establish probable cause to search a vehicle trunk?

The determination made in United States v. White emphasizes that the mere presence of the odor of marijuana in the passenger compartment of a vehicle is not sufficient on its own to establish probable cause to conduct a search of the vehicle's trunk. This ruling reflects a legal standard where probable cause must be established based on evidence that suggests criminal activity is occurring or has occurred, specifically tied to the area being searched.

The reasoning behind this conclusion centers on the premise that while the smell of marijuana may indicate illegal activity, it only pertains to the areas where the smell is detected, such as the passenger compartment. The trunk, being a separate compartment of the vehicle, would require additional indicators that justify suspicions linking the trunk to the suspected illegal activity.

In this context, probable cause needs a clearer connection to the specific area being searched. Factors such as the sight of a weapon or the presence of multiple passengers may suggest a heightened likelihood of illegal activity, which could more directly influence the justification for a search. However, the distinct odor of marijuana originating from the passenger compartment alone does not inherently extend to a reasonable assumption that contraband exists in the trunk without corroborating evidence.