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.