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Criminal Procedure keyed to Kamisar
Maryland v. Pringle
Citation:
540 U.S. 366, 124 S.Ct. 795, 157 L.Ed.2d 769 (2003)Facts
A police officer pulled over a car for speeding. The car was occupied by three people: the driver, a back-seat passenger, and Pringle who was sitting in the front seat. When the officer asked the driver for his license and registration, he noticed a large amount of rolled-up cash in the glove compartment. The officer ran a check on the driver’s license and registration, which did not reveal any violations. The officer asked the driver if he had any weapons or narcotics. The driver said he did not and consented to a search of the car. The officer found $763 in the glove compartment and 5 plastic baggies of cocaine from behind the backseat armrest. None of the men in the car offered information regarding ownership of the drugs, so they were all arrested.
Later that morning, Pringle confessed to owning the cocaine. At trial, Pringle filed a motion to suppress his confession as fruit of an illegal arrest, which the court denied. He was convicted of possession of cocaine and possession with intent to distribute cocaine. The Court of Appeals of Maryland reversed the conviction, holding that, absent specific facts tending to show Pringle’s knowledge and control over the drugs, the mere finding of cocaine in the car was insufficient to establish probable cause.
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