ISSUE: At 3:16 am, a police officer stopped a speeding a Nissan Maxima car model occupied by three men; Donte Partlow who was the owner and driver of the car, on the front seat was Pringle, the respondent, and Otis Smith, the back seat passenger. The officer asked Partlow for his license and registration. The officer saw a lot of money rolled-up in a glove compartment as the documents and became suspicious. He asked him to accompany him to the patrol car so that the officer could check for any violations from the computer system. The officer did not find any violations and so issued him an oral warning. Later another patrol car arrived, and the officer asked partlow whether he had carried any weapons or narcotics in the car. Partlow said no and allowed the officers to search his car. The officer found $763 in the car after a thorough search. In addition, there were five glassine baggies of cocaine hidden in the armrest of the backseat and the back seat. The officer then questioned the three men, but none admitted being the owner of drugs or money. He arrested them and took them to a police station for further questioning. The next morning, Pringle orally confessed that the drugs were his and that he was going to a party with his friends where he planned to sell the drugs or even use them ‘‘for sex’’. By making the oral confession, he waived his right under Miranda v. Arizona, 384 U. S. 436 (1966). He defended his friends that they were not aware that he had carried cocaine in the car. This led to the release of his friends.
RULE: Pringle’s confession did not suppress the trial court ruling. A jury convicted him of possessing cocaine and possession with intent to distribute cocaine. His sentence was 10 years’ incarceration and without any possibility of parole. The Court of Special Appeals of Maryland made affirmation of the case. 141 Md. App. 292, 785 A. 2d 790 (2001). The court of appeal of Maryland, though with divided vote, reverted the ruling. They argued that there was no specific proof to show that Pringle was the owner of the drugs. There was cocaine in the back armrest. Pringle was seated on the front passenger seat. In addition, its owner drove the car. According to the Fourth Amendment, made applicable to the states by the Fourteenth Amendment, people are secure in their homes, persons, papers, and effects and should never be subjected to unreasonable searches and arrest warrants shall be issued against them. However, upon probable cause, Maryland authorizes police officers to arrest without warranty,inter alia, any person believed to have committed a felony or is about to commit a felony. A warrantless arrest is, hence consistent with the Fourth Amendment as long as there is a probable cause to support the arrest, United States v. Watson, 423 U. S. 411, 424 (1976).
ANALYSIS: It is evident that the police officer had a justifiable reason to believe that a felony had been committed after he found five baggies containing cocaine. This is because there is a law prohibiting the possession of dangerous substances. Historical fact leading to the arrest needed to be looked into keenly in order to know whether the police officer was justified to arrest Pringle. The facts are that: Pringle was one of the occupants of the car. In front of him was glove inside of which was $763. Behind the back seat were five plastic glassine of cocaine, accessible to the three men. None of them admitted being the owners of money or cocaine. A reasonable officer could have concluded that the cocaine was Pringles’ or it belonged to the three men.
Pringle attempted to characterize the case as guilt by association by relying on Ybarra v. Illinois, supra, and United States v. Di Re, 332 U.S. 581 (1948). In this case, the police had received a warrant to search a tavern and its bartenders for controlled substances. Ybarra, one of the bar attendants had six tinfoil packets of heroin. The police had no authority to carry out body searches of all the patrons in the tavern according to the orders given. Pringle’s case was quite different as the three were not in a public tavern but a small automobile.
CONCLUSION: The huge amount of money found in the case could not be treated in isolation. The huge quantity of money and cocaine showed a probability of existence of drug dealing. It is also reasonable to think that the culprits will most likely not admit possessing the drugs because of the consequences faced if found guilty. The Court of Appeal of Maryland held that there was a probable cause to believe that Pringle had committed a felony. The judgment was reversed and remanded for further proceedings inconsistent with the opinion.