Maryland. The passenger, Mr. Pringle was accused of possession of drug and intent to distribute it. The main issues and questions that arose from the proceedings was whether the police officer had probable cause to arrest and convict the suspect (Lane, 2003. While the trial Court and Maryland’s Special Appeals Court convicted Pringle to serve a ten year sentence without a possibility of parole, the US Court of Appeals overturned the verdict and demanded that proceedings resume, but concrete substantiation be obtained to condemn the suspect.
This paper explores the Maryland versus Pringle case by discussing the issues and questions arising from the searches and arrests made. The paper also looks at the opinions of the trial Court, Maryland Special Appeals Court and the US Court of Appeals. The importance and the infringement of the 4th and the 14th Amendment by law enforcement officers are also discussed. Facts of Maryland versus Pringle Case Maryland versus Joseph Jermaine Pringle case took place before a trial Court, A Maryland Special Appeals Court, and the Court of Appeal and involved a car passenger named Pringle.
Pringle and two other occupants were stopped at dawn by a police officer for over speeding. The incident occurred on August 7, 1999 at 3. 15 in the morning. The car owner, Donte Carlos Partlow had two passengers, Joseph Jermaine Pingle in the front seat and Otis Calvin Smith at the back seat. A police officer named Jeffery Snyder waved down the car, asked for the driver’s license and in the process of retrieving it from the glove compartment, Partlow revealed a bundle of cash that raised the officer’s suspicion.
After searching the car, the officer found cocaine stashed behind the back-seat’s armrest (The Drug War Chronicle, 2003). The occupants were immediately arrested. In Maryland, the law allows police officers to arrest suspects without a warrant provided there is a cause to believe a crime was about to be committed. At the police station, the other occupants refused to divulge any information to the officers but Pingle, after obtaining a Miranda versus Arizona waiver from Officer Snyder, confessed his guilt.
The discovery of the cocaine was thus enough to convince the officer that a felony was being committed or about to be committed. Pringle was charged with possession of cocaine and intent to distribute it. He was sentenced to ten years imprisonment. Pringle appealed against the conviction in Special Appeals Court of Maryland that unfortunately upheld the ruling of the lower court. He again appealed, based on lack of proper cause for his arrest and conviction at the Court of Appeals (Lane, 200). Questions and Issues of the Case
Many issues and questions arise from the Maryland versus Pringle case: Was there reasonable evidence on which Pringle and the other occupants of the car could be searched and arrested? Why was Pringle the only suspect of possession and intent to distribute controlled substances? Did the court scrutinize the events leading to the arrest? When can a reasonable officer be convinced that a suspect is guilty? Was the officer reasonable not to jointly suspect all the occupants of the car? Did the officer breach the 4th Amendment by searching the occupants’ of the car?
Generally, the main issue raised by the case was whether a front seat passenger should be arrested and convicted for a drug found at the back seat of a car which was being driven by the owner. Courts’ Opinion The trial Courts verdict was that Pingle had knowledge of the existence of the cocaine in the car and he signed the confession by himself, further serving as evidence he was actually in possession of the drug (The Drug War Chronicle, 2003). The Court also believed there was reasonable evidence that Pringle committed the offence. The decision of the Court of Appeal was read by Justice Rehnquist, C. J. The jury‘s opinion was that since the officer had probable cause to arrest Pringle, the fourth Amendment was not violated. The other members of the jury included Justices Stevens, O’Connor, Scalia, Kennedy, Souter, Thomas, Ginsburg and Breyer. The Court of Appeals was of the opinion that Maryland’s Special Appeals Court also erroneously based its argument on the fact that an officer must not have all the necessary facts to execute an arrest. The Court had dwelt on the crime of drug possession and did not concentrate on the issue of probable cause of arrest.
The Court thus upheld the ruling of the trial Court without considering if there was a probable cause of arrest (Lane, 2003). The law requires that a certain level of suspicion only should be achieved before an individual is arrested and convicted from a group. The relaxation of the standards of probable cause seem to have been orchestrated to accommodate police officers’ mistakes while making arrests as observed in Brinegar versus United States. The trial court rejected Pringle appeals on grounds of unlawful arrest. The court held that the officer had reasonable grounds on which to arrest Pringle.
The jury thus convicted Pringle of cocaine possession with intent to distribute and sentenced him to ten years in prison. While the Courts of Special Appeals of Maryland affirmed the actions of the trial court, the Court of Appeal reversed the verdict. According to the Court of Appeal, finding the cocaine in the back seat armrest was not enough to convict a front seat passenger. The $ 763 found in the car did not imply it was from cocaine sales. The money was thus treated as a separate entity from the cocaine (Green, 2008).
The Court of Appeals however argued that the fact that the cocaine was found at the car’s back-seat was not enough to prove Pringle’s guilt, Ybarra v. Illinois, 444 U. S. 85, 91. The Court of Appeal felt that the fact that the cocaine was at the back seat while Pringle was at the front seat implied he may not have been in ownership of the drug. In addition, Pringle was a front seat passenger in a car driven by its owner. In any case, it was the owner of the car who was supposed to be arrested or prosecuted, not Pringle (Green, 2008).
The Court of Appeals felt that Pringle was not the sole occupant of the car and all the other occupants had equal chances of possessing the drug or being aware of its existence at the back of the back seat, Ornelas v. United States, 517 U. S. 690, 696. The existence of the cocaine at the back seat armrest did not link any particular occupant but implied that at least one of them knew of its existence. There was however, a concurring opinion that there was a probable cause to arrest all the three occupants of the car.
The fact that the officer narrowed down the arrest to the three suspects indicates he had reasonable cause to suspect them. Johnson v. United States and Wong Sun v. United States, are also cases which had many suspects but minimal arrests made. The Court of Appeals did not contest the fact that the officer had reasonable cause to arrest Pringle. The officer had cause to believe a felony was being committed, Brinegar v. United States, 338 U. S. 160, 176 (1949). The officer however needed to scrutinize the historical facts leading to the arrest to culminate in his arresting of the suspects (Lane, 2003).
The court of Appeals reversed the decision of the trial Court that was affirmed by the Special Appeals Court of Maryland. The Court of Appeals argued that the law prohibited any unreasonable seizures, searches or any form of infringement on individuals’ property and privacy. The Court further held that an arrest supported by probable cause by an officer who believes a crime is being committed is consistent with the Fourth Amendment. The sole question by the Appeals Court was whether the officer had probable cause to believe Mr. Pingle, and not the other occupants, possessed the drug (The Supreme Court, 2008).