This just in from the Utah Court of Appeals: too many air fresheners is sufficient cause for reasonable suspicion. From fourthamendment.com:
Overwhelming number and odd collection of air fresheners is reasonable suspicion. State v. Richards, 2009 UT App 397 (December 31, 2009):
¶1 This appeal presents the issue of whether a police officer had a reasonable, articulable suspicion that criminal activity was afoot so as to justify the investigatory detention of Defendant Heather Richards when the officer was confronted with the overwhelming smell of air fresheners and saw multiple odor masking agents such as orange rinds, Lysol, and Armor All. We conclude that the odd combination of odor masking agents and strong smells emanating from defendant’s vehicle are objective facts that gave rise to a reasonable, articulable suspicion that
Defendant was involved in drug trafficking.
Apparently, using too many air fresheners can be unwise. Who knew?