## Facts

- At about 3:16 a.m., a Baltimore County police officer stopped a Nissan Maxima for speeding; it had three occupants, including Joseph Jermaine Pringle in the front passenger seat.
- With the driver’s consent, the officer searched the car and found $763 in rolled-up cash in the glove compartment and five baggies of cocaine behind the back-seat armrest.
- All three occupants denied knowledge or ownership of the cash and cocaine and provided no information about who possessed them.
- The officer arrested all three occupants for drug offenses.
- After receiving Miranda warnings at the station, Pringle confessed that the cocaine was his and that the group intended to sell it or use it at a party.
- Pringle was charged with possession of cocaine and possession with intent to distribute; the trial court denied his motion to suppress his confession as the fruit of an unlawful arrest, and a jury convicted him.

## Issues

1. Whether the Fourth Amendment requires suppression of a confession obtained after arresting a front-seat passenger when drugs are found in a car and all occupants deny ownership.
2. Whether the discovery of cocaine hidden in the car and cash in the glove compartment, combined with the occupants’ denials, gave an objectively reasonable officer probable cause to arrest Pringle in particular.

## Decision

- The Supreme Court unanimously reversed the state high court.
- The Court held the officer had probable cause to arrest Pringle for possession of cocaine, either solely or jointly.
- Because the arrest was supported by probable cause, it did not violate the Fourth and Fourteenth Amendments.
- The case was remanded for further proceedings.

## Legal Principles

- Probable cause exists when, under the totality of the circumstances, an objectively reasonable officer has reasonable grounds to believe a person committed a crime.
- Probable cause must be particularized to the person seized, but it may be satisfied by reasonable inferences from circumstances indicating shared knowledge and control.
- When drugs and indicia of drug dealing are found in the confined setting of a car, and no occupant claims ownership, an officer may reasonably infer a common enterprise and arrest any or all occupants.
- Cases rejecting “guilt by association” in public settings do not control when the facts support a reasonable inference that vehicle occupants are jointly involved.

## Conclusion

The Court held that the presence of cocaine hidden in the car, a substantial amount of cash, and the occupants’ collective denial of ownership created probable cause to arrest the front-seat passenger, making his later Mirandized confession admissible against a Fourth Amendment challenge.


Maryland v. Pringle, 540 U.S. 366 (2003)