In the early morning hours a passenger car occupied by three men was stopped for speeding by a police officer. The officer, upon searching the car, seized $763 of rolled-up cash from the glove compartment and five glassine baggies of cocaine from between the back-seat armrest and the back seat. After all three men denied ownership of the cocaine and money, the officer arrested each of them. We hold that the officer had probable cause to arrest Pringle—one of the three men.
Under the Fourth Amendment, made applicable to the States by the Fourteenth Amendment, Mapp v. Ohio, 367 U. S. 643 (1961), the people are “to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, … and no Warrants shall issue, but upon probable cause … .” U. S. Const., Amdt. 4. Maryland law authorizes police officers to execute warrantless arrests, inter alia, for felonies committed in an officer’s presence or where an officer has probable cause to believe that a felony has been committed or is being committed in the officer’s presence. Md. Ann. Code, Art. 27, §594B (1996) (repealed 2001). A warrantless arrest of an individual in a public place for a felony, or a misdemeanor committed in the officer’s presence, is consistent with the Fourth Amendment if the arrest is supported by probable cause. United States v. Watson, 423 U. S. 411, 424 (1976); see Atwater v. Lago Vista, 532 U. S. 318, 354 (2001) (stating that “[i]f an officer has probable cause to believe that an individual has committed even a very minor criminal offense in his presence, he may, without violating the Fourth Amendment, arrest the offender”).
It is uncontested in the present case that the officer, upon recovering the five plastic glassine baggies containing suspected cocaine, had probable cause to believe a felony had been committed. Md. Ann. Code, Art. 27, §287 (1996) (repealed 2002) (prohibiting possession of controlled dangerous substances). The sole question is whether the officer had probable cause to believe that Pringle committed that crime.
The probable-cause standard is incapable of precise definition or quantification into percentages because it deals with probabilities and depends on the totality of the circumstances. See ibid.; Brinegar, 338 U. S., at 175. We have stated, however, that “[t]he substance of all the definitions of probable cause is a reasonable ground for belief of guilt,” ibid. (internal quotation marks and citations omitted), and that the belief of guilt must be particularized with respect to the person to be searched or seized, Ybarra v. Illinois, 444 U. S. 85, 91 (1979).
We think it an entirely reasonable inference from these facts that any or all three of the occupants had knowledge of, and exercised dominion and control over, the cocaine. Thus a reasonable officer could conclude that there was probable cause to believe Pringle committed the crime of possession of cocaine, either solely or jointly.
Full case at Maryland v. Pringle, 540 U.S. 366 (2003), https://supreme.justia.com/cases/federal/us/540/366/#tab-opinion-1961472
Anton Vialtsin, Esq.
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