Maryland v. Pringle

540 U.S. 366 (2003)

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Nature of the Case

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Facts

Police stopped a Nissan for speeding at 3 in the morning. There were three occupants in the car: Partlow, the driver and owner, D, the front-seat passenger, and Smith, the back-seat passenger. The officer asked Partlow for his license and registration. When Partlow opened the glove compartment to retrieve the vehicle registration, the officer observed a large amount of rolled-up money in the glove compartment. The officer returned to his patrol car with Partlow's license and registration to check the computer system for outstanding violations. The computer check did not reveal any violations. The officer returned to the stopped car, had Partlow get out, and issued him an oral warning. A second patrol car arrived, and Partlow was asked if he had any weapons or narcotics in the vehicle. Partlow indicated that he did not. Partlow then consented to a search of the vehicle. The search yielded $763 from the glove compartment and five plastic glassine baggies containing cocaine from behind the back-seat armrest. When the officer began the search, the armrest was in the upright position flat against the rear seat. The officer pulled down the armrest and found the drugs, which had been placed between the armrest and the back seat of the car. No one admitted to ownership of the drugs. All three were placed under arrest and transported to the police station. D waived his rights under Miranda and gave an oral and written confession in which he acknowledged that the cocaine belonged to him, that he and his friends were going to a party, and that he intended to sell the cocaine or 'use it for sex.' D maintained that the other occupants of the car did not know about the drugs, and they were released. The trial court denied D's motion to suppress his confession as the fruit of an illegal arrest, holding that the officer had probable cause to arrest D. D was convicted and appealed. The Court of Appeals of Maryland, reversed, holding that, absent specific facts tending to show D's knowledge and dominion or control over the drugs, 'the mere finding of cocaine in the back armrest when D was a front seat passenger in a car being driven by its owner is insufficient to establish probable cause for an arrest for possession.'