United States v. Prandy-Binett - 302 U.S. App. D.C. 1, 995 F.2d 1069 (1993)

Rule:

Probable cause is evaluated not only from the perspective of a prudent man, but also from the particular viewpoint of the officer involved in the search or seizure. Law enforcement officers naturally reach conclusions based on their training and experience. In cases of searches or seizures without warrants, the court's role is to decide whether the officer's inference from the facts was reasonable. This depends on information showing the officer's accumulated knowledge of criminal activity, information that must be in the record if it is to be considered.

Facts:

After spotting a rectangular package wrapped in plastic and duct tape in defendant Pedro Jolio Prandy-Binett’s gym bag, two plain-clothes detectives, believing the block contained illegal drugs, handcuffed defendant, examined the wrapped object further, and seized it and the gym bag. Defendant was charged with possession with intent to distribute 500 or more grams of cocaine, in violation of 21 U.S.C.S. § 841(a)(1), (b)(1)(B)(ii). The district court held that the detectives had violated defendant's Fourth Amendment rights and did not have probable cause to inspect his package, and dismissed the indictment. The federal government appealed.

Issue:

Under the circumstances, did the detectives have probable cause to arrest defendant, and to inspect his gym bag?

Answer:

Yes.

Conclusion:

The appellate court reversed the orders of the district court, holding that the detectives were not required to be aware of the specific crime a suspect was likely committing; it was enough that they had probable cause to believe that the suspect committed one or the other of several offenses, even though they could not be sure which one. The court found that the detectives' observations could not have been disregarded and that they had a solid foundation from which to evaluate relative frequency and to judge the percentage of times such packages held narcotics.