In Maryland v. Pringle, U.S Supreme Court convicted pringle on the basis that a probable cause existed when the police officer found cocaine in the car he was travelling in.
The court also held that the drugs could have belonged to any of the three passengers and as such, the police did not violate the fourth amendment when he arrested him bearing in mind that the passengers revealed neither possession nor ownership prior to the arrest. This paper will give brief background information of the fourth amendment; discuss a procedural history of the case as well as its significance.
Background of the Case
Maryland v. Pringle, 540 U.S. 366 (2003) is a U.S case in which a policemen stopped a car that had three passengers (partlow, pringle and smith) and requested for the driver’s (Partlow) registration. The driver reached for the glove compartment which had $ 763 kept in it and this aroused the policeman’s curiosity and as such he requested to conduct a search in the car. The driver allowed him and consequently, the policeman found cocaine that had been packed into five bags and hidden in the armrest.
The two passengers plus the driver denied knowledge and ownership of the cocaine and the policeman arrested them. The three were taken to a police station where Pringle confessed ownership of the drugs and the other passengers were set free. Prior to discussing the above case, brief background information of facts related to the case will be discussed. The fourth amendment protects citizens from harassment by police officers.
According to Humper (2007), U.S constitution (amendment four) states that “The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.” The fourth amendment requires that a warrant arrest and probable cause of arrest is given to the suspect before he or she is arrested.
Probable cause of arrest has been given various definitions depending on the circumstances but the underlying meaning is just the same. Understanding of the term probable cause is important for anybody to understand why the ruling in Pringle’s case by various courts. Another term that will be discussed briefly is individualized suspicion.
In simpler terms, probable cause implies that there is more evidence in support of the matter at hand as opposed to the evidence against the same matter. Probable cause can be further explained as having more than half (50%) of evidence that justifies the cause of action to take. Practically, courts do not follow the rule to the letter and it is applied depending on the circumstances of the situation.
When examining existence of probable cause, courts requires that a test known as the totality-of circumstances be utilized and tries to justify the situation from the perspectives of a prudent objective police officer. The rationale for using the totality-of-circumstances lies in the fact that the courts would find it difficult to arrive at probable cause if it relied on its own independent opinion. As such, the test is preferred despite the rigidities associated with it (Humper, 2007).
Individualized suspicion is a term that is closely related to probable cause since the court requires individualized suspicion for every probable cause. Individualized suspicion requires substantial connection between searches and seizures conducted by the police officers and the circumstances that led to such searches and seizures. This clause therefore limits the scope and circumstances under which the government and police officers may conduct such searches and seizures (Humper, 2007).
In addition to individualized suspicion, the fourth amendment also states that a warrant arrest should be issued before an arrest. However, there are some exceptions to the requirement if there is sufficient evidence that a crime or felony has been committed. It would be unreasonable for police officers to leave criminals to go and get a warrant. It goes without saying that the criminals would take to their heels and this would increase the crime rate (Humper, 2007).
Procedural History of the Case
Pringles trial was held at the Circuit Court for Baltimore County where he was found guilty justification being that the five baggies of cocaine belonged to him. Pringles case was appealed at the Mary land Court of special appeals. Pringle was not satisfied by the courts ruling since he felt that the evidence given was not sufficient to give a probable cause of his arrest.
Pringle’s argument was based on the fact that the requirement of individualized suspicion was not met when he was arrested since he was just a mere a passenger in a car in which the contraband was found. He relied on the requirement by the fourth amendment that an arrest should be accompanied by individualized suspicion.
He also relied on the English case law which has the same legal standing as fourth amendment about individualized suspicion. Pringle added that individualized suspicion was a major component of probable cause as stipulated by the United States Supreme Court (Maryland v. Pringle). His lawyer requested to suppress Pringles motion but the court concurred with the previous courts decision of denying Pringle a chance to suppress the motion. The court referred to folk test that was derived from (Folk v. State), case.
According to the folk test, the following factors should be put into consideration while ascertaining whether there is a probable cause. The distance between the accused and the contraband, ownership of the place where the contraband was kept, knowledge of contrabands existence by the accused as well as availability of circumstances from which it can be reasonably inferred that the accused was in partnership with others for common benefit.
In Folk v. state, the person who appealed happened to be a passenger in a car in which one of the passengers was smoking Marijuana. Folks attempted to suppress the marijuana’s motion but the court denied him a chance and stated that the appellant “could not be closer, short of direct proof that the appellant herself was in exclusive physical possession of the marijuana . . . .”
Proximity could not be more clearly established” (Folk v. state). Though the court quoted the folks test, it did not make use of it when considering Pringles case and instead assumed that the distance between the contraband and the defendant was close enough to ascertain existence of a probable cause.
The case was appealed again at the court of appeals of Maryland. The court reversed the decision taken by the other courts and held that there was insufficient evidence that Pringle was in possession of the cocaine since he was just a passenger in a car that was being driven by the owner. The court borrowed from Collins v. State, 589 A.2d 479, 480 (Md. 1991) case in which it was held that being close to the scene of crime is insufficient to ascertain the existence of a probable cause.
In Collins case, Collins happened to be among five men that were five feet from an automobile. A police officer came and requested one of the men to pick a film canister that was in the car’s backseat. Five packets of cocaine were found inside the film canister and the police officer arrested the five men. Since Collins was outside the car, the court held that there was insufficient evidence to hold a probable cause just because cocaine was found inside the car.
The decision of Maryland’s court of appeals was reversed by the United States Supreme Court which stated that the police officer had enough reason to infer that the cocaine belonged to all the three passengers since none of them disclosed ownership. The officer’s act of arrest was therefore justified and had not violated the fourth amendment.
The court held that there was enough evidence to reasonably infer that Pringle was guilty of being in possession of the contraband either solely or in partnership with the other passengers in the vehicle. United States Supreme Court had one question: was there evidence enough to support a probable cause that Pringle had committed the offence?
The court argued that if a group of two or more people was suspected to have committed an offence, then one of them is singled out as the criminal, then the others can not be held responsible unless otherwise stated.
The supreme court also held that Maryland court of appeal was not fair when it treated the cash found in the car as a different case as opposed to one of the circumstances leading to the arrest. Pringle was convicted and the ruling was made by Chief Justice William H. Rehnquist who had a unanimous agreement with the other judges.
Based on the ruling made by the state of Maryland court, it can be inferred that Pringles case was judged on the basis of probable cause by association as individualized suspicion requirement was not met. Probable cause by association is not included in the fourth amendment and as such, it can be referred to as an additional clause to the Fourth amendment.
This implies that a gateway to convicting innocent people had been opened by the ruling. The court ignored the fact that an innocent person can borrow a lift from a private car and as such, it is not his business to search the vehicle with an intention to ascertain that all the cargoes in the car are legal goods.
Significance of the Case
Mr. Howe’s has legal basis to suppress the arrest. Based on the above case, the passengers did not disclose ownership or possession of the drugs. However, at the police station, Pringer confessed that the drugs were his. The police officer could not have allowed the passengers to just drive off after he found the drugs.
Since he did not get any response, the officer had sufficient evidence to infer that a felony had been committed hence arrest all the occupants. However, the court did not apply the individualized suspicion requirement when ruling Pringles case. If Mr. Howe’s client’s circumstances are exactly the same, then there is no need to suppress the motion despite presence of legal basis.
Criminal Law – Probable Cause (1991). Collins v. State, 589 A.2d 479, 480. Retrieved http://www.courts.state.md.us/opinions/cosa/2001/705s00.pdf
Find Law: Folk v. State (1971). Folk v. State, 275 A.2d 184. Retrieved from http://caselaw.findlaw.com/ga-court-of-appeals/1395588.html
Gordon. R. (2003). You Ride With ‘Em, You Die With ‘Em. A Look at Maryland v. Pringle and the United States Supreme Court’s Implementation of Probable Cause by Association.
Maryland v. Pringle, 540 U.S. 366, 124 S. Ct. 795. Retrieved from
Humper, G. (2007). U.S Constitution 4th Amendment is dead in America http://www.youtube.com/watch?v=bB_jp3Sm1BY