Tuesday, November 5, 2013

Maryland v. Pringle case brief

Maryland v. Pringle case brief summary
540 U.S. 366 (2003)

Defendant was convicted of drug possession offenses but asserted that a police officer had no probable cause to arrest defendant based on drugs found in a vehicle in which defendant was a passenger. Upon the grant of a writ of certiorari, the State of Maryland appealed the judgment of the Court of Appeals of Maryland which held that defendant's arrest lacked probable cause.

In addition to the driver and a back set passenger, defendant was a front seat passenger in a vehicle which was stopped for speeding. Upon a consensual search, a significant amount of cash was found in the glove compartment of the vehicle and drugs were discovered between the back-seat armrest and the back seat. Although defendant subsequently admitted that the drugs and cash were his, none of the vehicle occupants admitted to ownership of the drugs at the time of the search, and all three occupants were arrested.


  • The United States Supreme Court held that the officer had probable cause to believe that defendant was in possession of the drugs. 
  • It was an entirely reasonable inference that any or all three of the occupants had knowledge of, and exercised dominion and control over, the drugs, and thus a reasonable officer could conclude that there was probable cause to believe defendant committed the crime of possession of drugs, either solely or jointly. 
  • It was also reasonable for the officer to infer a common enterprise among the three occupants, in view of the likelihood of drug dealing in which an innocent party was unlikely to be involved.

The judgment holding that defendant's arrest lacked probable cause was reversed, and the case was remanded for further proceedings.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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