Maryland v. Pringle
Encyclopedia
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.
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.
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.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
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
Cocaine
Cocaine is a crystalline tropane alkaloid that is obtained from the leaves of the coca plant. The name comes from "coca" in addition to the alkaloid suffix -ine, forming cocaine. It is a stimulant of the central nervous system, an appetite suppressant, and a topical anesthetic...
and possession of cocaine, and was sentenced to 10 years incarceration without the possibility of parole
Parole
Parole may have different meanings depending on the field and judiciary system. All of the meanings originated from the French parole . Following its use in late-resurrected Anglo-French chivalric practice, the term became associated with the release of prisoners based on prisoners giving their...
.
The Maryland Court of Special Appeals
Maryland Court of Special Appeals
The Maryland Court of Special Appeals is the intermediate appellate court for the U.S. state of Maryland. The Court of Special Appeals was created in 1966 in response to the rapidly growing caseload in the Maryland Court of Appeals. Like the state's highest court, the tribunal meets in the Robert C...
affirmed, but the Maryland Court of Appeals
Maryland Court of Appeals
The Court of Appeals of Maryland is the supreme court of the U.S. state of Maryland. The court, which is composed of one chief judge and six associate judges, meets in the Robert C. Murphy Courts of Appeal Building in the state capital, Annapolis...
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
Probable cause
In United States criminal law, probable cause is the standard by which an officer or agent of the law has the grounds to make an arrest, to conduct a personal or property search, or to obtain a warrant for arrest, etc. when criminal charges are being considered. It is also used to refer to the...
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
Fourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
and Fourteenth Amendments
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
to the United States Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
. Maryland law authorizes police officers to execute warrantless arrests where the officer has probable cause to believe that a felony
Felony
A felony is a serious crime in the common law countries. The term originates from English common law where felonies were originally crimes which involved the confiscation of a convicted person's land and goods; other crimes were called misdemeanors...
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
Brinegar v. United States
Brinegar v. United States, 338 U.S. 160, 176 , was an early Supreme Court case employing the "reasonableness test" in warrantless searches...
, 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
Ornelas v. United States
Ornelas v. United States, 517 U.S. 690 , was a case decided by the Supreme Court of the United States that held that appellate courts should review probable cause determinations for warrantless searches de novo.-Factual background:...
, 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.