ON WRIT OF CERTIORARI TO THE COURT OF APPEALS OF MARYLAND

Three men were riding in a passenger vehicle when a policeman pulled it over for going too fast. He demanded the driver’s identification and registration. The policeman noted there was a sizable sum of cash in the glove compartment as he was taking these out. The driver’s computer review did not turn up any violations. He received a verbal caution from the police officer. A second patrol car arrived and the driver was asked whether he was in possession of any narcotics and weapons. He refused and consented to a search. The search revealed an amount of cocaine. When the three passengers were questioned, they all denied knowledge and ownership of the drugs and were arrested.

Later, Pringle waived his Miranda rights and gave a confession, both oral and written. He acknowledged ownership of the cocaine and stated that his friends were not involved.

Procedural Posture: Pringle’s motion to suppress his confession based on an illegal arrest was denied by the trial court. It was held that there was a probable cause of arrest. The jury convicted him of intent to distribute and possession of cocaine. The decision was affirmed by the Court of Special Appeals of Maryland.

Issue:

Issue 1: Whether there was probable cause for the arrest of Pringle.

Holding: The Court of Appeals of Maryland reversed the decision. By divided vote, it held that in absence of facts showing Pringle’s knowledge of the drugs other than mere finding of the cocaine in the car, the probable cause for an arrest was not established. The court granted certiorari.

Rationale: The provisions of the Fourth Amendment state that warrants shall only issue upon probable cause (Rich). This was also held in the case of Mapp v. Ohio, 367 U. S. 643 (1961). In this case, it was stated that persons are to be secure against unreasonable searches and seizure. The scope of this security extends to the persons themselves, their papers, cars, houses and effects.

As per the decision in the case of Atwater v. Lago Vista, 532 U. S. 318, 354 (2001), a police officer may arrest an offender without violating the Fourth Amendment if he believes that a crime has been committed (James).

It was clear that there was a probable cause for arrest; possession and intent to distribute an illegal drug. However, there was no probable cause for the arrest of Pringle. The court cited the case of Wyoming v. Houghton, 526 U. S. 295 (1999) (Thomas). In this case, the court had noted that a passenger of a car would often have a common interest with the driver. As such, it would be more reasonable if the officer had treated all the three passengers alike. Furthermore, the amount of drugs and money in the car suggested drug dealing and it would be highly unlikely that a dealer would bring an innocent party so close to his dealings such that there would be danger that the person would furnish evidence against him.

Dissent/Comment/Significance/Impact: This case emphasizes the importance of the right of the security of the person and the provisions of the Fourth Amendment. The law enforcement officers have to exercise a lot of diligence in executing their duties. The privacy of the person should be respected as it is a constitutional right (Dean). Even further, the allowance that they may execute unwarranted arrests should be exercise within the limits of the law (Steven).

Works Cited

Dean, Galiano. The Fourth Amendment: Unreasonable Search and Seizure. The Rosen Publishing Group, 2011.

James, R Acker. Criminal Procedure: A Contemporary Perspective. Jones & Barlett Publishers, 2011.

Rich, Smith. Fourth Amendment: The Right to Privacy. ABDO, 2010.

Steven, Emanuel. Criminal Procedure. Aspen Publishers Online, 2009.

Thomas, N McInnis. The Evolution of the Fourth Amendment. Lexington Books, 2010.