What is the test for probable cause in a search for illegal drugs?

Citing People v. Limon (1993) 17 Cal.App.4th 524, 537, defendant argues the presence of a common container is not enough to establish probable cause. According to defendant, he was not stopped or arrested for a drug offense, the officer had no prior knowledge of defendant having any drug involvement, the officer did not smell drugs, and defendant did not appear to be under the influence of drugs. Defendant claims the officer had at most a "strong hunch" or reasonable suspicion. We disagree.

In reviewing the denial of a motion to suppress, we defer to the trial court's factual findings, express or implied, when supported by substantial evidence. (People v. Tully (2012) 54 Cal.4th 952, 979.) But we independently determine, on the facts found, whether the search was reasonable under the Fourth Amendment. (Ibid.)