Case Citation: Maryland v. Pringle, 540 US. 366 (2003)
Parties:
Maryland, Petitioner
Pringle, Respondent
Facts: In Baltimore County, Maryland State, police officer stopped the car for speed exceeding. Search performed by the police officer resulted revelation of drugs behind the car armrest and cash in the amount $763. Mr. Pringle, one of passengers in the car, was found guilty in drugs possession with further intention to distribute. Notwithstanding that passengers denied conviction of cocaine and money ownership, they were all arrested by the police officer. Pringle was sentenced to incarceration without the parole possibility for 10 years.
Procedural History:
Pringle waived his right according to the decision in Miranda v. Arizona, 384 U. S. 436 (1966) case. He gave a confession that he possessed the cocaine, which he intended to sell or use in the party. He confirmed his awareness of cocaine in the car. The trial court denied Pringle’s motion to suppress the confession as the police officer had a probable cause to arrest Pringle. The sentence was affirmed by the Maryland Court of Special Appeals. The Maryland Court of Appeals reversed previous sentence as it did not find presence of any specific facts confirming Pringle’s awareness or control over cocaine. Also, the cocaine in the back armrest was not found by the Maryland Court of Appeals as a sufficient evidence to justify “probable cause” to arrest Pringle for drugs possession. The case was presented before the US Supreme Court’s consideration.
Issues:
Whether the police officer arrested Pringle in accordance with Fourth and Fourteenth Amendments?
Holdings:
Yes. The US Supreme Court stated that the police officer had a probable cause to arrest Pringle. That is why his actions were in accordance with Fourth and Fourteenth Amendments of the US Constitution.
Reasoning:
a: “Probable cause” exception
The US Supreme Court held that Fourth and Fourteenth Amendment of the US Constitution warrants protection of individuals from unreasonable searches and seizures. Nevertheless, this rule has an exception. As it was found in case United States v. Watson, 423 U. S. 411, 424 (1976), arrest without a warrant is in accordance with the Fourth Amendment if it is maintained by probable cause. It applied decisions adopted in previously considered cases. It held that standard of probable cause is a nontechnical conception dealing with everyday life contemplation but not legal technics Illinois v. Gates, 462 U. S. 213, 231 (1983), see, e.g., Ornelas v. United States, 517 U. S. 690, 695 (1996); United States v. Sokolow, 490 U. S. 1,
7-8 (1989). Consequently, the Court found that it was obvious for the police officer to believe in probability of felony as he revealed five pouches containing cocaine. For that reason, the Court reversed lower court’s decision.
b: Guilt-by-association applicability
The Court found this criterion inapplicable. Pringle objected his guilt relying on Ybarra v. Illinois, 444 U. S. 85, 91 (1979) case circumstances. In Ybarra, the Court held that warrant to search the tavern together with its bartender was not a background to provide such search among customers. The Court applied decision adopted in Wyoming v. Houghton, …
