Maryland v. Pringle, Joesph (12/15/2003)

Questions presented: Where drugs and a roll of cash are found in the passenger compartment of a car with multiple occupants, and all deny ownership, does the 4th Amendment prohibit a police officer form arresting the occupants of the car?

BY RACHEL GREEN, MEDILL NEWS SERVICE

Joseph Pringle admitted at the police station that the five baggies of cocaine cops seized from his friends car were his. Hearing that evidence, a jury in Baltimore County Circuit Court convicted him of possessing drugs with the intent to sell and sentenced to 10 years in prison.

The issue at trial was whether his confession should be suppressed because his arrest was illegal.

Pringle was the front-seat passenger in Donte Partlows car in August 1999, when Baltimore County Police Officer Jeffrey Snyder pulled Partlow over for speeding. As Partlow reached across the passengers seat to retrieve his vehicle registration, Snyder noticed a wad of cash stuffed in the glove compartment.

Snyder asked the two men and a third companion whether they were hiding drugs or weapons in the vehicle and they said "no." Then Snyder asked the men to get out of the car as he searched the car for contraband with Partlows approval. Snyder found a total of .7 grams of cocaine shoved behind the armrest in the back seat, as well as $763 in cash stuffed into the glove compartment.

Again, Snyder said he asked the men who the drugs belonged to, and they all denied responsibility. At this point, Snyder arrested all three men and brought them to the police station for further questioning. Several hours later, Pringle admitted the cocaine was his and that he intended to sell it that night at a party, possibly in exchange for sex. After he signed a written confession, his two friends were promptly released.

At trial, his attorney tried to have the confession suppressed, claiming Officer Snyder violated Pringles 4th Amendment right prohibiting unlawful searches and seizures because his arrest lacked probable cause. The judge denied the motion, heard his confession, and the jury found him guilty.

A Maryland intermediate court ruled 2-1 in the states favor, affirming Pringles conviction. The majority concluded Snyder had sufficient evidence to suspect and arrest all three men in connection with the drugs, based on the circumstances in the case.

Pringle appealed to the Maryland Court of Appeals, the states highest court, which reversed by a 4-3 vote. Led by Justice Dale Cathell, the four-person majority found that Snyder had no reason to link Pringle with the money he saw in the glove compartment, and, by extension, had no basis to investigate Pringle for further wrongdoing.

"The mere finding of cocaine in the back armrest when [Pringle] was a front seat passenger in a car being driven by its owner is insufficient to establish probable cause of an arrest for possession," Cathell wrote, adding that Snyders threat to arrest all three men when none of them confessed was coercive and illegal.

Public Defender Sherrie Glasser, part of Pringles legal team, said the issue is not Pringles confession, but the way Snyder pressured him to confess. She said Snyder had no reason to link Pringle to the drugs found in the back seat.

"What were talking about here is not guilt or innocence, its probable cause," Glasser said. "With any 4th Amendment protection, there will always be some guilty people who get off, but there are thousands of non-guilty people who are saved."

Glasser said in cases like Pringles, the driver or the owner of a car should be held responsible for any contraband found inside. She called Snyders decision to arrest all three passengers in the car a "huge invasion."

But Maryland Court of Appeals Justice Lynne Battaglia wrote a strongly worded dissent, defending Snyders decision to arrest the three suspects.

"Probable cause for an arrest (a lower standard than legal sufficiency for a conviction) requires the reasonable belief that the person arrested had committed or was committing the felony crime of possession of narcotics," Battaglia wrote. Based on the specific facts in Pringles case, "a police officer could reasonably believe that those persons were exercising joint and constructive possession of the contraband in the vehicle, were engaging in drug trafficking, or conspiring to engage in drug trafficking, thus establishing probable cause for the arrest of each individual."

Battaglia concluded that police officers should never "base their arrests of suspected wrong-doers upon whether a conviction may stand." Reversing Pringles conviction, she said, effectively handcuffs the Maryland criminal justice system.

In his petition to the U.S. Supreme Court, Maryland Attorney General J. Joseph Curran, Jr., asked the Court to take a firm position on probable cause as it relates to a group of possible suspects in a crime.

On March 24, 2003, the Court accepted the case for review.

Maryland Solicitor General Gary Baer, who will argue the states appeal, said the case is crucial in determining the authority granted to police officers who suspect individuals of a crime.

"Police are going to have discretion of who theyre going to arrest, but they need guidance from the courts," Baer said, adding that a ruling against Maryland by the Supreme Court might scare police officers when making future arrests based on probable cause.

Baer said police officers need to use discretion when they notice suspicious activity. "With probable cause, it always comes down to the totality of the circumstances," he said.

Twenty states have joined an amicus brief spearheaded by Ohio in support of Marylands case. "Police officers need pretty clear-cut rules in these types of situations," Baer said. If the Court rules against the state, "it would make it more difficult for the officers to know (whom) to arrest," he added.

On Dec. 15, 2003, the Court sided unanimously with police, holding that they had probable cause to believe Pringle committed a crime by its discovery of money and cocaine in the car, and therefore to arrest him, question him and get a lawful confession out of him.

"Pringle's attempt to characterize this case as a guilt-by-association case is unavailing," Chief Justice William Rehnquist wrote for the Court. "Here we think it was reasonable for the officer to infer a common enterprise among the three men. The quantity of drugs and cash in the car indicated the likelihood of drug dealing, an enterprise to which a dealer would be unlikely to admit an innocent person with the potential to furnish evidence against him."