Maryland v. Pringle
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.
| Maryland v. Pringle | |
|---|---|
 | |
| Argued November 3, 2003 Decided December 15, 2003 | |
| Full case name | State of Maryland v. Joseph Jermaine Pringle |
| Docket no. | 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 |
| Case history | |
| Procedural | 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 | |
| |
| Case opinion | |
| Majority | Rehnquist, joined by unanimous |
| Laws applied | |
| U.S. Const. amends. IV | |
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
- List of United States Supreme Court cases, volume 540
- List of United States Supreme Court cases