State v. Toledo, 204 N.C. App. 170 (May. 18, 2010)

A search of a tire found in the undercarriage of the defendant’s vehicle was proper. An officer stopped the defendant for following too closely. The officer asked for and received consent to search the vehicle. During the consent search, the officer performed a “ping test” on a tire found inside the vehicle. When the ping test revealed a strong odor of marijuana, the officer arrested the defendant and searched the rest of the vehicle. At that point, the officer found a second tire located in the vehicle’s undercarriage, which also contained marijuana. The search was justified because the discovery of marijuana in the first tire gave the officer probable cause to believe that the vehicle was being used to transport marijuana and therefore the officer had probable cause to search any part of the vehicle that may have contained marijuana.