I noticed these two cases on FourthAmendment.com today.
Defendant was stopped for overtinting, and the officer could smell marijuana, the defendant was really nervous, and the car had 18 air fresheners hanging inside. The subsequent search produced 574 grams of cocaine. The search was valid. Richardson v. State, 2010 Ga. App. LEXIS 827 (September 8, 2010).
Defendant was stopped for a traffic offense, and the car had the overwhelming odor of air freshener, defendant could not say where he was going, and he was getting increasingly nervous as the stop continued. That was reasonable suspicion. Wilson v. State, 2010 Ga. App. LEXIS 853 (September 10, 2010).
It is fair to say that in each case the police officer put forward additional facts along with the nice smell.