A police officer of Baltimore County, Maryland stopped a car for speeding. Three men were on the car. Partlow was the owner and driver of the vehicle. Pringle was at the front passenger seat. Smith was at the back seat. When the driver opened the glove compartment to get the car registration, the police officer noticed a sizable amount of rolled-up cash inside. The police officer proceeded to verify the registration and check the driver’s license. Partlow had no prior criminal record. The police officer asked for permission to search the car. When the officer pulled down the rear armrest, he found five baggies of cocaine placed in between the armrest and the backseat. The officer asked the three people in the car about the drugs. All three men said that they did not know about the drugs found inside the vehicle. The police officer seized the baggies of cocaine and the rolled-up cash and arrested the three men. At the police station, Pringle waived his right to remain silent and admitted that he was the owner of the baggies of cocaine and his two companions were not aware of the drugs in the car. Pringle was charged and convicted of possession with intent to sell. His two companions were released. On appeal, the Maryland Court of Appeals reversed the conviction on the ground that the arrest was not lawful. There was no sufficient probable cause to arrest Pringle for possession. The driver was the rightful owner of the car. Pringle was seated at the front passenger side. The cocaine baggies were found at the backseat.
Issue
Is there sufficient probable cause to arrest Pringle along with the driver and the backseat passenger of a car driven by its owner after finding baggies of cocaine between the backseat and rear armrest?
Holding
Yes. Sufficient probable cause exists to arrest Pringle and his companions in the car after the police officer discovered baggies of cocaine between the backseat and rear armrest.
Rationale
The Court reiterated the principle that probable cause rests on the consideration of the full context or conditions surrounding the case. The situation relating to the case should not be segmented and each aspect of the context should not be isolated. In ruling that there was no probable cause to arrest all three car passengers, the Maryland Court of Appeals only considered the baggies of cocaine found between the backseat and rear armrest in isolation from the sizable rolled-up cash found on the glove compartment. According to the Supreme Court, the totality of the circumstances indicate that Pringle was one of the passengers of a car, which a police officer stopped for speeding at 3:16 A.M. Rolled-up cash totaling $763 was in the glove compartment facing Pringle, who was seated at the front passenger side. Five cocaine baggies were found in between the backseat and rear armrest. All three passengers have access to the area where the baggies of cocaine were found. None of the passengers initially admitted knowledge about the baggies of cocaine and the cash. The baggies of cocaine and large amount of cash indicate that one, two or all car passengers were selling drugs. Even if none of the three car passengers sold drugs, it was likely that they knew about the drugs in the car and/or the owner of the drugs and money. The driver owns the car. Drug dealers are also not likely to entrust their product and money to people with no involvement with their drug dealing. People who are not involved in drug dealing are likely to testify against drug dealers. Based on the consideration of the full context surrounding the arrest, the Court held that the police officer had sufficient probable cause to arrest all three passengers of the car.
Reference
Maryland v. Pringle, 540 U.S. 366 (2003).
