Maryland v. Pringle Case Brief

Facts of the case

A police officer stopped a car for speeding, searched the car, and seized money from the glove compartment and cocaine from behind the back-seat armrest. The officer arrested the car’s three occupants after they denied ownership of the drugs and money. A state court sentenced Pringle, the front-seat passenger, for possessing and intending to distribute cocaine after he signed a written confession. The state appellate court reversed the conviction, holding that the mere finding of cocaine in the back armrest when Pringle was in the front-seat of a car being driven by its owner was insufficient to establish probable cause for arrest for possession.

Why is the case important?

Pringle appealed a conviction, based on lack of probable cause, when he was arrested for paraphernalia found in the back of another person’s a car, while sitting in the front.

Question

Whether the arrest of a front-seat passenger in a car driven by its owner lacks probable cause in violation of the Fourth Amendment when the basis for the arrest is paraphernalia found in the back of the car.

ANSWER

When finding contraband in an automobile, there is probable cause to arrest its occupants, regardless of their proximity from the contraband.

CONCLUSION

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.

  • Advocates: Gary E. Bair argued the cause for Petitioner Sri Srinivasan argued the cause for Petitioner, on behalf of the United States, as amicus curiae Nancy S. Forster argued the cause for Respondent Steven R. Shapiro for the American Civil Liberties Union et al. as amici curiae urging affirmance Lisa Kemler for the American Civil Liberties Union et al. as amici curiae urging affirmance
  • Petitioner: Maryland
  • Respondent: Joseph Jermaine Pringle
  • DECIDED BY:Rehnquist Court
  • Location: –
Citation: 540 US 366 (2003)
Granted: Mar 24, 2003
Argued: Nov 3, 2003
Decided: Dec 15, 2003
Maryland v. Pringle Case Brief