Facts of Case: Three men were riding around about three a.m. on the morning of August 7, 1999 when they were caught speeding by a Baltimore County Police Officer. Donte Partlow, owner of the Nissan Maxima, was driving. The front seat passenger was the defendant Joseph Jermaine Pringle. The rear passenger was Otis Smith. When Partlow took his registration out of the glove compartment, the officer noticed some “rolled-up money in the glove compartment.” After running a warrant check that turned out clean, the officer just gave Partlow a warning about speeding.
After the first officer issued a warning for speeding, a second officer arrived on the scene. The second officer asked if Partlow “had any weapons or narcotics in the vehicle.” Partlow denied having these items. The second officer asked if he could search the vehicle and Partlow said yes. The search turned up $763 in the glove compartment and five plastic bags containing cocaine. The cocaine was in the back seat armrest. All three men in the vehicle denied ownership of the drugs and the money. However, the next morning, Pringle signed a confession stating that the drugs were his. He also stated that Partlow and Smith did not know the drugs were in the vehicle.
Pringle was convicted of “possession with intent to distribute cocaine and possession of cocaine.” In 141 Md. App. 292, 785 A.2d 790 (2001), the Court of Special Appeals of Maryland affirmed the lower court’s decision. The Court of Appeals of Maryland in 370 Md. 525, 545, 805 A, 2d 1016, 1027 (2002) reversed, stating that there were no facts indicating that Pringle knew of or controlled the drugs. This brings the case to the United States Supreme Court.
The United States Supreme Court believes that after discovering the drugs, “the officer had probable cause to believe that Pringle had committed the crime of possession of a controlled substance according to Maryland v. Pringle, 540 U.S. 366 (2003). The Supreme Court held that Pringle’s arrest did not violate either the Fourth or the Fourteenth Amendments.
Issue: Per “Md. Ann. Code, Art. 27, § 277 (s) (1996) (repealed 2002)”, did the police officer have “probable cause to believe that Pringle committed” the crime of “actual or constructive dominion or control over a thing by one or more persons?”
Rule: According to Brinegar v. United States, 338 U.S. 160, 175 (1949), probable cause is “a reasonable ground for belief of guilt.” Determining whether an officer has probable cause includes examining “the events leading up to the arrest” and whether a reasonable and objective officer would find probable cause to arrest someone according to standards determined in.
Analysis: At the time of the arrest, Maryland did have a law in place allowing police officers to complete searches without warrants if the officer suspected a felony or a misdemeanor had been committed in the officer’s presence. This law has since been repealed. Md. Ann. Code, Art. 27, § 277 (s) (1996) (repealed 2002). The Maryland law at the time of the arrest was considered to be within the bounds of Fourth Amendment rights.
Naturally, after the second officer found the cocaine, he had reason to believe a crime had been committed. The incident should have never gotten this far as the search should have never taken place. The first officer on the scene was releasing the driver with a warning. Not everyone who is stopped for a traffic violation has his or her vehicle searched.
The Supreme Court ignores the fact that the search should have never taken place. The Supreme Court instead focuses on which of the three occupants of the car knew about and controlled the cocaine. The Supreme Court says that after discovering the drugs, a reasonable officer could believe that any of the three occupants individually or jointly could be guilty of the crime of possession of cocaine. The Supreme Court goes on to state that they “think it was reasonable for the officer to infer a common enterprise among the three men” Maryland v. Pringle, 540 U.S. 366 (2003).
Conclusion: The Supreme Court relied on Maryland’s law, Md. Ann. Code, Art. 27, § 277 (s) (1996) (repealed 2002), that was in force at the time of the arrest, to believe “that Pringle had committed the crime of possession of a controlled substance” Maryland v. Pringle, 540 U.S. 366 (2003). No Fourth or Fourteenth Amendment rights were violated according to the Supreme Court. The Supreme Court reversed “the judgment of the Court of Appeals of Maryland” and remanded the case “for further proceedings not inconsistent with this opinion” ibid.
The case is no longer significant as the law relied on has since been repealed. Even though the search should have never happened, at the time, the arrests were valid based on the law at the time and based on the evidence found. If the search had never happened, the case would have never gone to trial. No one would have been found guilty of a crime.
