Scope of search warrant based on marijuana odor

QUESTION PRESENTED This case is about the scope of a search warrant based on the mere odor of burning marijuana. During a knock-and-talk at Petitioner Melvin Jones’s house, police officers smelled the scent of marijuana smoke; they later observed a small, stillsmoldering marijuana cigarette on top of an open trash can. Based on this, they obtained a warrant to search the entire home, including locked containers, for items as varied as additional drugs, firearms, and electronic devices. Inside a locked safe in Mr. Jones’s bedroom, police found a handgun. He argued that the warrant lacked probable cause and was overbroad. The Fourth Circuit upheld the search, holding as a categorical matter that the smell of burning marijuana alone provided sufficient probable cause for police to search the entire house, including locked containers that could not have been the source of the odor. The Fourth Circuit’s ruling deepened a longstanding disagreement among state and federal courts. The question presented: Does probable cause to believe that a small, personaluse amount of drugs is present in a home automatically also provide probable cause to search the entire home (including locked containers inside it) for additional drugs, on the theory that where there is as little as one marijuana cigarette, more drugs are likely to be hidden nearby?