What is the test for probable cause to search for marijuana under the Fourth Amendment?

Probable cause to search exists "where the known facts and circumstances are sufficient to warrant a man of reasonable prudence in the belief that contraband or evidence of a crime will be found . . . [citations]." (Ornelas v. United States (1996) 517 U.S. 690, 696.) The existence of probable cause must be determined in context of the facts and circumstances of an individual case. (Ibid.)

Here, the officers smelled marijuana when they approached appellant, and he told them he had just smoked marijuana. These facts support the reasonable belief that he was in possession of marijuana. Thus, the officers had probable cause to search him for that substance. (People v. Strasburg (2007) 148 Cal.App.4th 1052, 1059 [probable cause to search for marijuana when officers smelled marijuana, defendant said he had just smoked marijuana and officers saw a bag of marijuana in defendant's vehicle].) Because the officers had probable cause to search appellant, the Fourth Amendment did not require exclusion of the handgun they discovered during that search.