Maryland v. Pringle
540 U.S. 366, 124 S. Ct. 795, 157 L. Ed.2d 769 (2003)

  • The police stopped a car driven by Partlow (Pringle and Smith were passengers). When the policeman asked for his registration, Partlow opened the glove compartment, revealing a pile of cash. The policeman asked for consent to search the car, which Partlow gave. A search turned up some cocaine, and the three men were arrested.
  • Pringle later confessed that the drugs were his.
  • The Trial Court convicted Pringle of drug possession. He appealed.
    • Pringle argued that the police had no probable cause to arrest Pringle and therefore his confession should be suppressed.
    • Basically Pringle argued that there was no individualized suspicion since the drugs could have belonged to anybody in the car. There was probable cause that someone in the car committed a crime, but there was no probable cause that Pringle committed a crime.
      • It was just a case of guilt by association.
  • The Maryland Supreme Court reversed and overturned the conviction. The prosecutor appealed.
    • The Maryland Supreme Court found that there were no specific facts to show that Pringle had knowledge or control of the drugs. The mere fact that there were drugs in the car did not establish probable cause to arrest Pringle.
  • The US Supreme Court reversed the Maryland Supreme Court and upheld the conviction.
    • The US Supreme Court found that since none of the three men offered any information on how the drugs got there, it was reasonable to assume that any or all of them owned the drugs. Therefore there was sufficient probable cause to conclude that Pringle had committed the crime of drug possession.
    • The Court found that it was reasonable to assume that the passengers of a car are all “engaged in a common enterprise with the driver, and have the same interests.”
      • That’s only because a car is small. If it were a larger area, like a bar, then there would not have been probable cause to arrest everyone in the bar.
        • See Ybarra v. Illinois (444 U.S. 85 (1979)).
      • If there was reason to believe that a particular person in the car was the guilty one, then there would not have been probable cause to arrest everyone in the car.
        • See United States v. DiRe (332 U.S. 581 (1948)).
        • Counterintuitively, that means that the less specific information the police have, the wider their search and seizure powers become.