Chisolm v. Maryland
In brief
The Supreme Court refused to hear Chisolm's case, leaving the Maryland ruling in place without deciding whether the vehicle search was lawful.
- Where it stands
- Decided
Decided · May 18, 2020
- What it’s about
- The Supreme Court denied review of Chisolm’s case, leaving the Maryland court’s ruling in favor of the State in place.
- Who it affects
- The Maryland ruling against Chisolm remains in place, but the Supreme Court did not decide whether either basis made the search lawful.
Summary: written with AI from the case record.

What it's about
The case concerned whether police could search Chisolm’s vehicle based only on the odor of marijuana and whether the search was valid as a search incident to arrest.
The dispute concerned a Maryland ruling for the State about whether police could search Chisolm's vehicle based on marijuana odor alone or as a search incident to arrest.
Question presented
1. Did the Court of Special Appeals err in its determination that the odor of marijuana, by itself, provided the police with probable cause to search Petitioner’s vehicle? 2. Did the Court of Special Appeals err in its determination that the search of Petitioner’s vehicle was a valid search incident to arrest?
What the Court decided
Holding
Petition DENIED.
What's next
The Supreme Court has finished this docket action. The Maryland ruling remains in place in Chisolm's case.
Documents
Opinions
Key filings
Docket activity
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AI analysis generated: Case Briefing
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Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.