Maryland v. Pringle

In Maryland v. Pringle, 540 U.S. 366 (2003), a police officer stopped a car for speeding. Id. at 368. The car was occupied by three men: the driver, the back-seat passenger, and respondent Joseph Pringle (Pringle), who was the front-seat passenger. Id. Based on the driver's consent, the police searched the car and recovered $ 763 in cash from the glove compartment and five glassine baggies containing cocaine concealed behind the upright back-seat armrest. Id. When none of the three occupants admitted to ownership of the cocaine or money, the police arrested them all. Id. at 368-69. Pringle later confessed that the cocaine belonged to him and that he intended to sell the cocaine or use it to obtain sex. Id. at 369. Based on these facts, the United States Supreme Court held that there was probable cause to arrest Pringle as well as the other two occupants of the car for possession of cocaine. We think it an entirely reasonable inference from these facts that any or all three of the occupants had knowledge of, and exercised dominion and control over, the cocaine. Thus a reasonable officer could conclude that there was probable cause to believe Pringle committed the crime of possession of cocaine, either solely or jointly. Id. at 372. Accordingly, the Supreme Court reversed the Maryland Court of Appeals which had held that Pringle's confession must be suppressed as the fruit of an unlawful arrest. Id. at 374. The United States Supreme Court held that it was "an entirely reasonable inference from these facts that any or all three of the occupants had knowledge of, and exercised dominion and control over, the cocaine. Thus, a reasonable officer could conclude that there was probable cause to believe the defendant committed the crime of possession of cocaine, either solely or jointly." (Id. at p. 372.) Pringle stands for the proposition that there is probable cause to arrest a passenger in a vehicle where there is evidence from which a reasonable officer may draw an inference that the passenger is jointly involved in criminal activity.