A police officer stops a speeding vehicle early in the morning. Aboard are three men identified as Donte Partlow, who is the owner and the driver at the time, there is also Joseph Jermaine Pringle, who is the respondent to this case and was occupying the front passenger seat at the time, and there is the backseat passenger identified as Otis Smith.
When the police officer in question requests for the vehicle’s registration, the driver gets it promptly from the glove compartment and, while doing so, the police officer astoundingly sees a large amount of money rolled up in the car’s glove compartment. It is later confirmed that the total amount of money found was $783, after a search that the police officer conducted in full consent of Partlow, the owner of the car.
According to the research, there were found 5 plastic baggies with a substance that was identified as cocaine. The bags were hidden at the arm of the backseat and, as such, each of the three men could have access to the bags. With the registration of the car and the driver’s license, the officer moves to his vehicle to check for any prior violations and finds none. Once he moves back to the stopped vehicle, he gets the driver to step out and issues him with an oral warrant of arrest. At around this time another police patrol car arrives and the three men are taken into custody. Later on, Pringle confesses to the police that he was the owner of the drugs and that he intended to sell or use them for sex.
The police officer found drugs in the backseat of the car and an amount of money that was totaled to $783.This served as proof to probable cause of committing a felony. The huge amount of money found on the suspect further pointed to the direction of probable involvement in drug dealing activities.
The officer questioned the three men, in the bid to ascertain the source of the money and drugs, about who owned the drugs and told these men that, if no one responded in the required way, it would lead to their arrest. No one gave any information regarding the ownership of the drug and at around that time another police car appeared and the three were arrested.
Pringle further confessed to possess the drugs and even indicated that his fellow occupants had nothing to do with them neither did they know of their existence. This was also seen a sufficient cause to believe that a felony was being committed and therefore did not violate the Fourth Amendments by arresting Pringle alongside the other two men.
At the lower court, Pringles lawyer brought forth an argument that his arrest had been unlawful since it had not been preceded by a probable cause that could clearly show his intention to commit a felony and that the prosecution was solely dependent on his confession. Nonetheless, the judge found that the police officer had enough reason to believe that a felony had been committed and as such sentenced Pringle to 10 years imprisonment without the possibility of a parole.
The court of Appeal of Maryland affirmed this ruling holding that the police officer had indeed probable cause to believe that a felony had been committed attributing to the existence of the drugs and Pringle’s confession to possession of those drugs.
However the Supreme Court overturned this decision and held that there had not been prove beyond reasonable doubt that Pringle indeed had any links to drug dealing activities. It observed that the mere fact that drugs had been found in a car on Pringle’s front seat passenger and his confession of ownership of these drugs was not evidence enough to sustain a conviction.
Is confession of ownership of drugs found at the arm-rest of the backseat of a small car that was being driven by its owner reason enough to believe that there were intentions to commit a felony?
The ruling was written by Chief Justice Rehnquist joined by Justices Stevens, Ocnor, Scolia. Kennedy, Soute, Thomas, Ginsberg and Brayer. The opinion for the Supreme Court was delivered by chief Justice Rehnquist
Analysis: Decision and Rationale
The court held that it was not enough for the prosecution to claim that a front seat passenger, who had confessed to possession of drugs found in the car and the knowledge of which other occupants of the car knew nothing about, to be taken as indication enough that there were intentions to commit a felony. It challenged that there must be a direct link between the narcotics and the suspected dealer.
Drug dealing is a highly profitable business. The presence of such an amount of drugs in the car and an equally large amount of money tended to point that there was likelihood of drug dealing. However, there was no likelihood for a potential dealer to so easily secure the release of would be co-accused as did Pringle. Thus, there was no sufficient evidence to show that Pringle in deed knew about the drugs and that he expressed any dominion or prior association with drug related activities.
The officer who led the procedure of arrest had sufficient reasons to suspect that the respondent, Pringle either as an individual or in association with the other occupants in the car had violated the law by owing the cocaine.
At trial, Pringle argued that “his confession was a fruit of an illegal arrest and should therefore be suppressed” (McCarthy, 2003) he claimed that his arrest did not have any legal ground and thus, could not be a valid reason for him being accused and imprisoned. However the jury found that the officer had reasonably been convinced that there was reason for arrest since, in his judgment there was intention to commit a felony by being in possession of and intending to distribute substance under control.
Additionally, the Supreme Court asserted that the standards for arrest under probable cause are apparently significantly higher than mere suspicion. Nonetheless, the Supreme Court states that there is far much less that is required as proof in order to secure a viable conviction. To this regard, the Supreme Court emphasized that the state is obliged to establish that suspect on whom drugs are found had verifiable knowledge of the drug in his/her possession or any other substance which is found in his/her possession. In other words, it has to be ascertained whether the suspect in possession of the drugs was aware of its presence and had a significant relationship to the drug.
In the instances where “drugs have been found in houses occupied or owned by more than one person; joint ownership and control cannot be assumed” (McCarthy, 2003). Instead, there has to be an ultimate attribution of the drug or drugs in the house to a person or people residing in the premises in question (Wayne et al.)
Brinegar v. United States, 338 U. S. 160, 176 (1949).
Illinois v. Gates, 462 U. S. 213, 231 (1983)
Miranda v. Arizona, 384 U. S. 436 (1966),
Ornelas v. United States, 517 U. S. 690, 695 (1996);
United States v. Watson, 423 U. S. 411, 424 (1976);
370 Md. 525, 545, 805 A. 2d 1016, 1027 (2002).
The Supreme Court overturned the Court of Appeal of Maryland’s ruling with a majority vote of 4-3 and ruled that possessing the nsubstance of any nature is enough ground for belief of guilt it was necessarily for the there to be comprehensive link of to the person or person found in possession of the substance(Raymond). The court established a new rule that suspects must be particularly linked to the substance they have been found in possession (McCarthy).
The dissent opinion which, as per the case records, was written at the Court of Appeal of Maryland authoritatively purported that the majority had used the probable cause standard for making an arrest.
Additionally, there was abundance of evidence standard for a conviction which was not supposed to be the case since it might have been interpreted to mean that there had been a wrong application of double standards.
The dissent at the Supreme Court argued that the opinion of the majority would bring about tendencies of police officers to base their arrest on whether the case might stand thereby overstepping their mandate.
In addition, the two cases that were cited by the majority had conspicuous differences with the present case observing that since finding two marijuana seeds in the front seat doesn’t soundly and sufficiently establish h probable cause to arrest the passenger at the back seat doesn’t necessarily mean that the presence of several cocaine sachets and the discovery of a large amount of money fails to meet the standards of probable cause. A large amount of money translates to lack sufficient probable case.
This case may set precedence and there are several ways in which it could be used to suppress the arrest and resulting statements. First, Mr. Howe will need to show a lack of a clear connection between his client and the contraband in question (McCauliff). It has been established that such acts as confession to ownership of a substance does not necessarily amount to pleading guilty. There must be indisputable link. Majority opinion had held that there is much less evidence required by a finding of probable cause to sustain an opinion.
Further Mr. Howe may need to establish the circumstances under which his client arrested law and whether a warrant of arrest was issued either orally or was The Fourth Amendment requires that suspects be fully informed of the pending arrest and the Maryland laws allows warrantless arrests. As such Mr. Howe may seek to find out whether the arrest was procedurally done.
Significance of the Case
Essentially, the precedence set by this case laid a foundation for many other cases of its kind—with several cases existing today having used this case as a point of reference. In addition, through the case, the moral lesson with regards to the possession of drugs was greatly emphasized.
Even more importantly, through this case, a new law was duly established with regards to drug possession. According to Andrew, based on the arguments in the Maryland v. Pringle, the court established a new rule that suspects of drug possession must be particularly linked to the substance found in their possession. This is majorly based on the fact that some people can be found in possession of drugs when in real sense, they do not know anything about the drugs. It is therefore safe to say that this new law goes a long way in protecting innocent people accused of possession of drugs.
Raymond, Margaret. “Down on the Corner, Out in the Street: Considering the Character of the Neighborhood in Evaluating Reasonable Suspicion”. Ohio State Law Journal, 1999. Print.
McCarthy, Kevin E. Probable Cause to Arrest-Drugs in Motor Vehicles. 2003. Web.
McCauliff, Chris. Burdens of Proof: Degrees of Belief, Quanta of Evidence, or Constitutional Guarantees. 1982. Web.
Wayne, Lafave R., Israel H Jerold and Nancy J King. Criminal Procedure. Racine, Wisconsin: West Publishing Company, 2009. Print.