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Maryland v. Pringle

Brief Fact Summary. Pringle appealed a conviction, based on lack of probable cause, when he was arrested for paraphernalia found in the back of another person’s a car, while sitting in the front.

Synopsis of Rule of Law. When a reasonable officer can conclude that a defendant is guilty, probable cause exists.

Facts. Respondent, Pringle, was the front-seat passenger in a car that was stopped for speeding. Upon stopping the car, the arresting officer found money in the glove compartment and cocaine in the back-seat armrest. The officer arrested all three occupants of the car and Pringle was convicted for possession with intent to distribute cocaine after he signed a written confession. Pringle appealed, arguing that probable cause to arrest him did not exist.

Issue. Whether the arrest of a front-seat passenger in a car driven by its owner lacks probable cause in violation of the Fourth Amendment when the basis for the arrest is paraphernalia found in the back of the car.

Held. When finding contraband in an automobile, there is probable cause to arrest its occupants, regardless of their proximity from the contraband.

Discussion. There is no violation of the Fourth Amendment ban against unreasonable searches and seizures when a reasonable officer can conclude probable cause in his arrest.