of marijuana, probable cause-not merely reasonable suspicion-may exist. See id. ("It is well settled that the odor of marijuana emanating from a vehicle establishes probable cause for the war-rantless search of that vehicle.") (citation and internal quotation marks omitted). Utah courts have also recognized that other odors can lead to a probable cause determination. See, e.g., State v. Bartley, 784 P.2d 1231, 1235 (Utah Ct.App.1989) (noting that the odor of "drip gas" coming from an automobile was key in establishing probable cause to justify a warrantless search of a truck). Courts in other jurisdictions have likewise concluded that the odor of drugs is sufficient to establish probable cause. See, eg., Johnson v. United States, 333 U.S. 10, 12-16, 68 S.Ct. 367, 92 L.Ed. 436 (1948) (<HOLDING>); Umited States v. West, 219 F.3d 1171, 1179
holding that the smell of marijuana gave the police probable cause to search the vehicle holding that the smell of burning opium was sufficient to establish probable cause holding that because of officers experience detection of the smell of cocaine smoke reliably supported a probable cause determination holding that a determination of probable cause does not bar a state law malicious prosecution claim where the claim is based on the police officers supplying false information to establish probable cause holding that a smell associated with pcp was enough to establish probable cause