Law School Case Brief
Maryland v. Pringle - 540 U.S. 366, 124 S. Ct. 795 (2003)
The substance of all the definitions of probable cause is a reasonable ground for belief of guilt, and the belief of guilt must be particularized with respect to the person to be searched or seized. To determine whether an officer had probable cause to arrest an individual, a court examines the events leading up to the arrest, and then decides whether these historical facts, viewed from the standpoint of an objectively reasonable police officer, amounted to probable cause.
During a 3:16 a.m. stop, by a county police officer in Maryland, of a relatively small car for speeding, the officer (1) observed a large amount of rolled-up money in the glove compartment when the driver-owner opened the compartment to retrieve the car's registration; and (2) performed, with the owner's consent, a search of the car that yielded $763 from the glove compartment and cocaine from behind the back-seat armrest. After none of the car's three occupants, when questioned by the officer, offered any information regarding ownership of the cocaine or the money, the officer arrested all three occupants and transported them to a police station. At the station, the accused, who had been the car's front-seat passenger, admitted that the cocaine belonged to him and stated that the other two occupants of the car had not known about the cocaine. The other occupants were released. In a Maryland court, the accused was (1) convicted of possession with intent to distribute cocaine and possession of cocaine, and (2) sentenced to 10 years' incarceration without the possibility of parole. The Maryland Court of Special Appeals affirmed. However, the Court of Appeals of Maryland reversed, holding that the officer had lacked probable cause to arrest the accused for possession of cocaine. Petitioner State sought further review.
Does the warrantless arrest of an automobile passenger during a stop for speeding violate the Fourth Amendment, where a police officer, having seized $763 from glove compartment and cocaine from behind back-seat armrest, arrested all three occupants after each denied ownership of cash and cocaine?
On certiorari, the Supreme Court of the United States held that a warrantless arrest of an automobile passenger during a stop for speeding did not contravene the Fourth Amendment, where police officer, having seized $763 from glove compartment and cocaine from behind back-seat armrest, arrested all three occupants after each denied ownership of cash and cocaine. The Court explained that the probable-cause standard is incapable of precise definition or quantification into percentages because it deals with probabilities and depends on the totality of the circumstances. The Court held that the officer here had probable cause to believe that defendant was in possession of the drugs. It was an entirely reasonable inference that any or all three of the occupants had knowledge of, and exercised dominion and control over, the drugs, and thus a reasonable officer could conclude that there was probable cause to believe defendant committed the crime of possession of drugs, either solely or jointly. It was also reasonable for the officer to infer a common enterprise among the three occupants, in view of the likelihood of drug dealing in which an innocent party was unlikely to be involved. The judgment holding that defendant's arrest lacked probable cause was reversed, and the case was remanded for further proceedings.
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