Today in History – Maryland v. Pringle

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Today in History – Maryland v. Pringle

2017-09-05T10:24:47+00:00August 7th, 2017|History, Legal Updates|Comments Off on Today in History – Maryland v. Pringle

Today in 1999,  at 3:16 a.m., Officer Jeffrey Snyder of the Baltimore County Police Department stopped a car for speeding and for the driver’s failure to wear a seatbelt.  Inside the vehicle were: Donte Partlow, the driver and owner of the car; respondent Joseph Pringle, who was seated in the front passenger seat; and Otis Smith, who was seated in the backseat. When Partlow opened the glove compartment to retrieve his registration, the officer noticed a large roll of money. After determining that there were no outstanding violations or warrants for Partlow, the officer gave Partlow, who was standing outside the vehicle, a verbal warning. Officer Snyder then asked for and received Partlow’s consent to search the car. All three men were frisked and asked to sit on the curb. The search disclosed $763 from the glove compartment and five glassine plastic baggies containing cocaine that

Officer Snyder then asked for and received Partlow’s consent to search the car. All three men were frisked and asked to sit on the curb. The search disclosed $763 from the glove compartment and five glassine plastic baggies containing cocaine that was hidden from view in the backseat armrest.  Officer Snyder questioned the men separately about the drugs and told them that unless he was told who possessed the drugs, “you are all going to get arrested.” None of the men offered any information regarding the money or drugs, and all were arrested. Two hours later at the police station, respondent confessed to owning the cocaine. Pringle told Officer Snyder that Partlow and Smith did not know or have anything to do with the money or drugs. Partlow and Smith were later released.

Pringle was charged with possession of cocaine and with possession with intent to distribute cocaine. At the trial court denied his motion to suppress, and the Maryland Court of Special Appeals affirmed. The Maryland Court of Appeals reversed the appellate court’s ruling and held there was no probable cause to arrest respondent. The court explained that the facts did not show that respondent had knowledge and dominion or control over the drugs.  Accordingly, the court held that “a police officer’s discovery of money in a closed glove compartment and cocaine concealed behind the rear armrest of a car is insufficient to establish probable cause for an arrest of a front seat passenger, who is not the owner or person in control of the vehicle, for possession of the cocaine.”

This Court granted certiorari to decide the following question: Where drugs and a roll of cash are found in the passenger compartment of a car with multiple occupants, and all deny ownership of those items, is there probable cause to arrest all occupants of the car?

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.

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John Blackmon

A retired law enforcement officer who now serves as the President of the Fraternal Order of Police Tri-County Lodge #3.
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