Mathias, J.
In this interlocutory appeal, Jesse Bunnell challenges the Greene Superior Court’s summary denial of his motion to suppress evidence allegedly obtained through an unlawful search and seizure of his home. On the unique facts of this case, we find that the search-warrant affidavit failed to provide the warrant issuing judge with a substantial basis for its probable-cause determination. Because there was no probable cause to issue the warrant, the search of Bunnell’s home was unlawful.
We reverse.
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Bunnell presents several arguments on appeal, one of which we find dispositive: whether the initial search-warrant affidavit supplied the issuing judge with a substantial basis for concluding there was probable cause to search his home.
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Here, Bunnell argues that the initial search-warrant affidavit failed to provide the judge with a substantial basis for finding probable cause. More specifically, he notes that “the only evidence that supports” probable cause is the deputies’ detection of the odor of raw marijuana, which was based on their “training and experience.” Appellant’s Br. at 20–21. But because there is no information about either deputies’ relevant training or experience in detecting the odor of raw marijuana, Bunnell contends that the affidavit is insufficient to establish probable cause. He thus asserts that the seized evidence pursuant to both the initial search warrant and the subsequently issued warrant must be suppressed. The State disagrees, maintaining that “the odor of raw marijuana with an identifiable source justified the magistrate’s initial probable-cause determination.” Appellee’s Br. at 13.
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On these unique facts and circumstances, we agree with Bunnell. To explain why, we address a narrow issue of first impression: whether law enforcement’s detection of the odor of marijuana based on unspecified “training and experience” by itself provides a warrant-issuing judge with a substantial basis for concluding that probable cause exists to search a home.
Over seventy years ago, the Supreme Court of the United States declared that “the presence of odors” can establish probable cause to issue a search warrant if two conditions are met: (1) the issuing judicial officer “finds the affiant qualified to know the odor”; and (2) the odor “is one sufficiently distinctive to identify a forbidden substance.” Johnson v. United States, 333 U.S. 10, 13 (1948).
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In short, we recognize that the smell of marijuana emanating from a residence, when detected by law enforcement that is qualified to identify and distinguish the odor, by itself can establish probable cause for issuance of a search warrant. But when the smell of marijuana is the only evidence constituting probable cause, the search-warrant affidavit—or information otherwise before the issuing judge—must include some information regarding the detecting officers’ relevant qualifications, experience, or training in identifying and distinguishing the odor.
To conclude otherwise would sanction a categorical presumption that every law-enforcement official is adequately trained in detecting and distinguishing the smell of marijuana. But such a presumption would conflict with Johnson’s mandate that a warrant-issuing judge find the “affiant qualified to know the odor” to constitute probable cause, 333 U.S. at 13, which must “be decided based on the facts of each case,” Figert v. State, 686 N.E.2d 827, 830 (Ind. 1997). While we are mindful that search warrants should not be invalidated by interpreting affidavits “in a hyper technical, rather than a commonsense, manner,” we must also “conscientiously review the sufficiency of affidavits on which warrants are issued” to ensure probable cause is not “a mere ratification of the bare conclusions of others.” Gates, 462 U.S. at 236, 239. We believe our holding today strikes the appropriate balance.
With these principles in hand, we now turn to the search-warrant affidavit here to determine whether it provided the issuing judge with a substantial basis for concluding that there was probable cause to search Bunnell’s home.
Thus, probable cause to search Bunnell’s home must be established solely by the deputies’ detection of the odor. 7 But the affidavit does not include any information regarding the deputies’ relevant qualifications, experience, or training that demonstrates either deputy can identify or distinguish the smell of raw marijuana. There is no information on how long either deputy had been in law enforcement. There is no information on either deputy’s involvement in investigating marijuana offenses or in making marijuana-related arrests. And there is no information about specialized training that either deputy had undergone in detecting the odor of raw marijuana. Simply put, the search warrant affidavit is devoid of particular information or evidence from which the warrant-issuing judge could find that either Deputy Elmore or Deputy Anderson were “qualified to know the odor” of raw marijuana emanating from the second-floor door of Bunnell’s residence. Johnson, 333 U.S. at 13; see United States v. Ventresca, 380 U.S. 102, 108–09 (1965) (observing that probable cause cannot “be made out by affidavits which are purely conclusory, stating only the affiant’s . . . belief that probable cause exists without” providing detailed circumstances on which the belief is based).
We acknowledge that Deputy Elmore cites both his and Deputy Anderson’s “training and experience” generally; and we give “due weight to inferences drawn from . . . local law enforcement officers,” Ornelas v. United States, 517 U.S. 690, 699 (1996). See United States v. Floyd, 740 F.3d 22, 35 (1st Cir. 2014) (recognizing that “a law enforcement officer’s training and experience may yield insights that support a probable cause determination”) (emphasis added). Yet, by not including any information about relevant training or experience— and with no other incriminating evidence or information from which to draw a reasonable inference of criminal activity—a judicial officer reviewing the affidavit must resort to multiple inferences, resulting in a tenuous rather than a substantial basis for finding probable cause. Indeed, if we were to conclude that unspecified “training and experience” alone provides the requisite substantial basis, we would be granting the three words talismanic qualities. See State v. Benters, 766 S.E.2d 593, 603 (N.C. 2014) (finding an affidavit “insufficient to establish probable cause” when concluding otherwise would require “such a heavy reliance upon officers’ training and experience”). And in doing so, we would be abdicating our role to ensure that warrant-issuing judges do “not serve merely as a rubber stamp for the police.” Ventresca, 380 U.S. at 109. This we will not do.
In sum, law enforcement’s detection of the odor of raw marijuana emanating from Bunnell’s second-floor door is the affidavit’s sole basis for establish probable cause to search the home. Yet, the affidavit does not include any information about the deputies’ relevant qualifications, experience, or training from which a warrant-issuing judicial officer could find either deputy qualified to identify or distinguish the odor of raw marijuana. Thus, the affidavit failed to provide the warrant-issuing judge with a substantial basis for its probable-cause determination. Because there was no probable cause to issue the warrant, the initial search of Bunnell’s home was illegal, and the exclusionary rule requires suppression of the evidence seized. Further, “it was by exploitation of that illegality” that law enforcement secured a search warrant for Bunnell’s RV. Wong Sun v. United States, 371 U.S. 471, 488 (1963). As a result, that evidence must also be suppressed. See id.
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When probable cause for a search warrant is premised solely on law enforcement’s detection of the odor of raw marijuana, the assertion must be based on more than personal belief: the affiant–officer must provide some information about the detecting officers’ relevant “training” or “experience” that led to the ultimate conclusion. The search-warrant affidavit here failed to include that information, and thus, the warrant-issuing judge did not have a substantial basis for its probable-cause determination. The search warrant was therefore invalid and the subsequent search illegal. As a result, the trial court erred when it summarily denied Bunnell’s motion to suppress.
Reversed.
Altice, J., and Weissmann, J., concur.