MELISSA COLEY v. STATE OF MARYLAND
Court of Special Appeals, Rodowsky, Filed Dec. 20, 2013,
Probable Cause- Where an officer observed a known drug user inside of a vehicle along with small, torn ziplock bags that in his expert opinion were frequently used to package heroin, probable cause existed to search the vehicle.

Does the law allow for the “almost Newtonian proposition that the discovery of some contraband suggests the likely presence of more contraband yet to be discovered”?

They Coley court says “Yes!”

That question, left open for some reason in Bell v. State, 96 Md. App. 46, 55 (1993), should not have taken 20 years to answer…

Though perhaps the answer’s not as obvious to everyone, because in this case “[t]he State concedes error. We disagree with the State’s conclusion, however, and, for the following reasons, we shall affirm Coley’s convictions.”

Good job, State…