Maryland v. Pringle

Maryland v. Pringle

Argued November 3, 2003
Decided December 15, 2003
Full case name State of Maryland v. Joseph Jermaine Pringle
Docket nos. 02-809
Citations

540 U.S. 366 (more)

124 S. Ct. 795; 157 L. Ed. 2d 769; 2003 U.S. LEXIS 9198; 72 U.S.L.W. 4103; 2003 Cal. Daily Op. Service 10763; 17 Fla. L. Weekly Fed. S 83
Argument Oral argument
Procedural history Writ of Certiorari to the Court of Appeals of Maryland
Holding
The arrest did not violate the Fourth Amendment because the officer had probable cause to arrest Mr. Pringle.
Court membership
Chief Justice
William Rehnquist
Case opinions
Majority Rehnquist, joined by unanimous
Laws applied
U.S. Const. amends. IV

Maryland v. Pringle, 540 U.S. 366 (2003), is a Supreme Court of the United States case regarding the reasonableness of the arrest of a passenger in an automobile.

Background

A police officer stopped a car for speeding at 3:16 a.m.; searched the car, seizing $763 from the glove compartment and cocaine from behind the back-seat armrest; and arrested the car's three occupants after they denied ownership of the drugs and money.

Mr. Pringle, the front-seat passenger, was convicted of possession with intent to distribute cocaine and possession of cocaine, and was sentenced to 10 years incarceration without the possibility of parole.

The Maryland Court of Special Appeals affirmed, but the Maryland Court of Appeals reversed, holding that, absent specific facts tending to show Pringle's knowledge and dominion or control over the drugs, the mere finding of cocaine in the back armrest when Pringle was a front-seat passenger in a car being driven by its owner was insufficient to establish probable cause for an arrest for possession of drugs.

Court's opinion

Chief Justice Rehnquist delivered the opinion for a unanimous Court.

Because the officer had probable cause to arrest Pringle, the arrest did not contravene the Fourth and Fourteenth Amendments to the United States Constitution. Maryland law authorizes police officers to execute warrantless arrests where the officer has probable cause to believe that a felony has been committed or is being committed in the officer's presence. Here, it is uncontested that the officer, upon recovering the suspected cocaine, had probable cause to believe a felony had been committed; the question is whether he had probable cause to believe Pringle committed that crime.

The "substance of all the definitions of probable cause is a reasonable ground for belief of guilt," Brinegar v. United States, 338 U. S. 160, 175, and that belief must be particularized with respect to the person to be searched or seized, Ybarra v. Illinois, 444 U. S. 85, 91. To determine whether an officer had probable cause to make an arrest, a court must examine the events leading up to the arrest, and then decide "whether these historical facts, viewed from the standpoint of an objectively reasonable police officer, amount to" probable cause. Ornelas v. United States, 517 U. S. 690, 696.

As it is an entirely reasonable inference from the facts here that any or all of the car's occupants had knowledge of, and exercised dominion and control over, the cocaine, a reasonable officer could conclude that there was probable cause to believe Pringle committed the crime of possession of cocaine, either solely or jointly. Reversed and remanded.

See also

External links

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