Maryland v. Pringle

Supreme Court of the United States · 2003 · Criminal Procedure

540 U.S. 366 (2003)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentProbable CauseWarrantless Arrestswarrantless arrestautomobile stopconstructive possessionjoint possession

Facts

At 3:16 a.m., a police officer stopped a car for speeding; the car contained the driver/owner, Pringle in the front passenger seat, and a rear-seat passenger. After the driver consented to a search, the officer found $763 of rolled-up cash in the glove compartment directly in front of Pringle and five plastic glassine baggies of cocaine behind the back-seat armrest, accessible to all three occupants. When questioned, none of the men admitted ownership of the drugs or money or provided information about them. The officer arrested all three men, and later that morning Pringle confessed that the cocaine belonged to him.

Issue

Whether, after finding cocaine in a car occupied by three men, along with rolled-up cash, and after all three denied ownership or gave no information, the officer had probable cause to arrest Pringle, the front-seat passenger, for possession of cocaine.

Rule

Probable cause is a practical, nontechnical standard based on the totality of the circumstances and asks whether the historical facts, viewed from the standpoint of an objectively reasonable police officer, amount to a reasonable ground for belief of guilt particularized to the person seized. In a car setting, where contraband and related evidence are accessible to multiple occupants and the circumstances reasonably support an inference of a common enterprise, probable cause may exist to arrest an occupant for possession, either solely or jointly.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

At 1:40 a.m. in Phoenix, Officer Lena Ortiz lawfully stopped a sedan for a broken taillight. The driver consented to a search, and Ortiz found eight small packets of methamphetamine in a pouch tucked between the rear seat cushions and a bundle of tightly folded bills in the center console; the driver and two passengers all said nothing when asked whose items they were.

Did Officer Ortiz have probable cause to arrest the front-seat passenger for possession of a controlled substance?

Explanation. Probable cause is assessed under the totality of the circumstances from the standpoint of an objectively reasonable officer. In a small car, where packaged drugs are accessible to all occupants, cash suggesting drug activity is present, and no one identifies an owner, an officer may reasonably infer a common enterprise and joint possession particularized to an occupant, including the front-seat passenger.