Is the smell of ether sufficient to provide probable cause for a search?

These Federal decisions share a similar rationale. Ether is only one of many chemical ingredients required to manufacture PCP and related drugs. Moreover, ether has many legitimate uses around homes, repair shops, and the like. Among other functions, it serves as a common solvent and is used to start engines. Accordingly, the odor of ether, unlike the odor of burning marijuana or other contraband, is consistent with lawful as well as criminal activity. It is not the equivalent of smelling the illicit drug itself. Hence the presence of ether, whether detected by the sense of smell or other senses, cannot supply probable cause for a search or an arrest without some further [144 Cal.App.3d 1055] evidence establishing the chemical probably is being used for an illegal purpose, rather than one of its many legitimate functions. (United States v. Tate, supra, 694 F.2d at p. 221.)