Analysis of the Case of Maryland v. Pringle - Assignment Example

Maryland v. Pringle, 540 U.S. 366 (2003) The case of Maryland v. Pringle, 540 U.S. 366 (2003) is an important case which deals with the Fourth Amendments prohibition of unreasonable searches and seizures. It deals with the criteria of probable cause for an arrest of an individual. Following paragraph briefs the facts of the case and the procedural history. A police officer stopped a car that was over speeding. There were three men in the car: Donte Partlow, the driver and owner of the car, Mr. Pringle, the passenger in the front seat and Otis Smith, the passenger in the back seat. While verifying the license and registration of Partlow, the officer observed a roll of cash in the glove compartment. On searching the car he found $763 in the glove compartment and cocaine in the armrest of the backseat. Money was found in the glove compartment directly opposite to Mr. Pringle and cocaine was found in the back seat armrest behind Mr. Pringle. Both cocaine and money were accessible by all the three men in the car. The officer seized the money and cocaine found in the car and arrested the three occupants in the car as none of them accepted the ownership of the cocaine and the money found in the car. Mr. Pringle, the passenger in the front seat was sentenced for the possession and the intent to distribute cocaine after he accepted the ownership. Under Miranda v. Arizona, 384 U. S. 436 (1966), he waived his rights and a written confession was signed by Mr. Pringle. Mr. Pringle’s motion to suppress his confession by stating that it was a result of an illegal arrest was denied by trial court. The court held that it was not an illegal arrest as the arrest by the officer was justified by a probable cause. Mr. Pringle was sentenced by the trial court for a period of 10 years without an option of parole. But the Court of Appeals of Maryland reversed the conviction stating that there wasn’t enough evidence to show that Mr. Pringle had any knowledge or control of the cocaine found in the car. It held that the fact that Mr. Pringle was in the front seat of the car driven by the owner from the back armrest of which cocaine was found is not enough to establish or prove a probable cause for arresting Mr. Pringle for possession. And hence the conviction of the trial court was reversed by the appellate court. The main question or issue in front of the court is whether there is a lack of probable cause and violation of the Fourth Amendments prohibition of unreasonable searches and seizures if a front seat passenger of a car which is driven by the owner is arrested as cocaine was found in the back armrest of the car? The Ruling of the court was that the arrest of Mr. Pringle by the officer was justified as he had a probable cause to believe that a crime was committed Mr. Pringle by possessing cocaine. Hence, it was concluded that Fourth and Fourteenth Amendments were not contravened by the arrest of Mr. Pringle. The court reversed the judgment of the Court of Appeals of Maryland and for further proceedings the case was remanded. The court decided based on the evident facts that the officer had a probable cause to arrest Mr. Pringle. That is because Mr. Pringle was among one of the 3 men in the car and $763 was found directly in front of Mr. Pringle in the Glove compartment. And behind Mr. Pringle in the back seat armrest was the packets of cocaine. Both the money and cocaine was accessible to all the three men in the car. As either of them take responsibility or ownership for the money and cocaine on questioning, it is reasonable to believe that either one of them had knowledge or control over the cocaine. And hence there is a probable cause to arrest all the three men involved. Therefore the court concluded that a reasonable officer has a probable cause to arrest Mr. Pringle. The court uses various cases to come to this conclusion. Illinois v. Gates (1983) is primarily used to define probable cause. The court defines probable cause as a non-technical and practical conception which depends on practical and factual evidence. It sates that probable cause is a fluid concept and can not be reduced to a set of legal rules. Therefore probable cause is judged on the reasonable ground for belief of guilt. The court concluded that Mr. Pringle’s claim of illegal arrest relying on Ybarra v. Illinois (1983) and United States v. Di Re (1948) is misplaced. In Ybarra police had a warrant to search the tavern and its bartender. They suspected the possession of controlled substance. But once in the tavern the police officers conducted a search of all the employees in the tavern. Ybarra was one of the customers and on searching heroin which is a controlled substance was found with Ybarra. But, there was no probable cause for the police officer to search Ybarra as they had warrants only to search Tavern and the bartender. The warrant did not permit the officers to search everyone at Tavern. Hence there is no probable cause to justify the search of Ybarra. In this case all the three involved were in a car which is not a public place as Tavern and it is reasonable to assume that all the three men have same interest. And all the factual evidence indicated the association of the three involved. In De Re, an investigator was informed by an informant that Reed would be receiving counterfeit gasoline ration coupons from Buttitta at a certain place. On reaching the place, investigator found out that as mentioned Reed had the gasoline ration coupons and was seated in the back seat of the car. There were two members in the car, Buttitta in the driver’s seat and Di Re in the passenger’s seat in the front. All the three men in the car were arrested. But there was no probable cause to arrest Di Rein as there was no prior information or factual evidence of Di Re possessing the coupons. Hence, there was nothing that pointed towards De Re committing the crime. Bit in this case there was no prior information on the crime and the all the three involved did not take responsibility for the cocaine found. Hence, it was concluded that the officer had a probable cause to arrest Mr. Pringle. The judgment was unanimous and there was no concurring or dissenting opinions. Cases Cited Illinois v. Gates, 462 U. S. 213, 231 (1983) Ybarra v. Illinois, 444 U. S. 85, 91 (1979). United States v. Di Re, 332 U. S. 581(1948) The case is of great significance as the ruling provided a framework for future cases on probable causes. It defined probable causes for better understanding and discussed criteria to judge probable causes scenarios. It modified the old law and gave officers more freedom and also guided to make decisions based on factual evidence. Read More