Opinion · Supreme Court of the United States

Maryland v. Pringle

Md. v. Pringle, 540 U.S. 366 (2003)

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
2003-12-15
Topic
general

How later courts describe this case

  • holding that “the belief of guilt must be particularized with respect to the person to be searched or seized”
  • holding that probable cause existed to arrest a passenger seated in the front of a car on a charge of possession of cocaine where police discovered cocaine in the backseat
  • holding that "[t]he substance of all the definitions of probable cause is a reasonable ground for belief of guilt"
  • holding that police officers had probable cause to arrest all three occupants of a vehicle where cocaine was accessible to all three
  • recognizing that an officer may make a warrantless arrest of a person in a public place if supported by probable cause
  • holding that probable cause existed to arrest all of a vehicle’s occupants after police discovered cocaine and money over which no occupant claimed possession
  • concluding that the officer had probable cause to arrest all occupants of a vehicle based on drugs and cash found therein
  • holding that large amount of drugs in vehicle provided probable cause to believe any of three men in vehicle had committed crime

Citator

UpLaw has not yet analyzed Maryland v. Pringle. The absence of a flag is not a finding that it is good law.

Authority status
pending
Cited by
1596 opinions
Distinguished
1 times

Headnotes

  1. Criminal Law & Procedure — Fourth Amendment A warrantless arrest of an individual in a public place for a felony, or for a misdemeanor committed in the officer's presence, is consistent with the Fourth Amendment if the arrest is supported by probable cause. United States v. Watson, 423 U.S. 411, 424 (1976); Atwater v. Lago Vista, 532 U.S. 318, 354 (2001)
  2. Criminal Law & Procedure — Probable Cause The probable-cause standard is a practical, nontechnical conception dealing with the factual and practical considerations of everyday life on which reasonable and prudent persons, not legal technicians, act; it is a fluid concept incapable of precise definition or quantification into percentages because it turns on the assessment of probabilities in particular factual contexts and depends on the totality of the circumstances. Illinois v. Gates, 462 U.S. 213, 231–232 (1983); Brinegar v. United States, 338 U.S. 160, 175 (1949)
  3. Criminal Law & Procedure — Probable Cause The substance of all the definitions of probable cause is a reasonable ground for belief of guilt, and that belief of guilt must be particularized with respect to the person to be searched or seized. Brinegar v. United States, 338 U.S. 160, 175 (1949); Ybarra v. Illinois, 444 U.S. 85, 91 (1979)
  4. Criminal Law & Procedure — Probable Cause To determine whether an officer had probable cause to arrest an individual, a court must examine the events leading up to the arrest and then decide whether those 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 (1996)
  5. Criminal Law & Procedure — Probable Cause Where drugs and a large quantity of cash are found in a relatively small automobile occupied by several persons and accessible to all of them, and none of the occupants offers any information regarding ownership of the contraband, it is an entirely reasonable inference that any or all of the occupants had knowledge of and exercised dominion and control over the drugs; a reasonable officer may therefore conclude that probable cause exists to believe a passenger committed the crime of possession of cocaine, either solely or jointly. 540 U.S. 366, 371–372, 373–374
  6. Criminal Law & Procedure — Probable Cause A person's mere propinquity to others independently suspected of criminal activity does not, without more, give rise to probable cause to search or seize that person, and the requirement of particularized probable cause cannot be avoided merely because probable cause coincidentally exists to search or seize another or to search the premises where the person happens to be. Ybarra v. Illinois, 444 U.S. 85, 91 (1979)
  7. Criminal Law & Procedure — Probable Cause A car passenger, unlike an unwitting patron of a public tavern, will often be engaged in a common enterprise with the driver and share the same interest in concealing the fruits or evidence of their wrongdoing; where the quantity of drugs and cash in the car indicates the likelihood of drug dealing, it is reasonable for an officer to infer a common enterprise among the occupants, since a dealer would be unlikely to admit an innocent person with the potential to furnish evidence against him. Wyoming v. Houghton, 526 U.S. 295, 304–305 (1999)
  8. Criminal Law & Procedure — Probable Cause Any inference that everyone on the scene of a crime is a party to it must disappear where the Government informer singles out the guilty person; no such singling out occurs where none of the vehicle's occupants provides information regarding ownership of the contraband. United States v. Di Re, 332 U.S. 581, 594 (1948)
  9. Criminal Law & Procedure — Probable Cause In assessing probable cause, a factor such as the presence of money must be considered as part of the totality of the circumstances rather than in isolation, since money alone may be innocuous but may contribute to probable cause when combined with other facts and circumstances within the officer's knowledge. Illinois v. Gates, 462 U.S. 213, 230–231 (1983); Brinegar v. United States, 338 U.S. 160, 175–176 (1949)