Maryland V. Pringle

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

Facts: A police Officer Snyder stopped a car for speeding on August 7, 1999 at 3:16 a.m. Partlow, the owner of the vehicle was driving the car, Pringle was the front seat passenger, and Smith was the back seat passenger. Officer Snyder asked Partlow for his driver’s license and the registration. When Partlow opened the glove box to grab his vehicle registration, Officer Snyder saw a large quantity of rolled up cash. After, checking Partlow’s license and registration with the Maryland Motor Vehicle Department. Officer Snyder gave Partlow a verbal warning and returned the documents back to Partlow and asked if he had any drugs or weapons in the car, Partlow answered no. Officer Snyder asked Partlow for consent to search the vehicle and Partlow said yes. The Officer then asked the other two passengers, Pringle and Smith to join Partlow on the curb next to car. The search of the front seat area revealed $763.00 in cash from the glove box. The search of the back seat area, led to the discovery of a Ziploc bag containing five smaller bags of crack cocaine. The officer found the drugs when he folded down the rear seat armrest. Officer Snyder questioned the three occupants of the car, one at a time, about the drugs and money. The officer first questioned Partlow, which said nothing. He next spoke with Pringle and Smith, who also refused to give any information. Officer Snyder advised Pringle that if no one claim the drugs, that they all would be arrested. Officer Snyder arrested all three occupants after they denied ownership of the drugs and money. The state court sentenced Pringle, the front- seat passenger, for possessing and intending to distribute cocaine after he signed a written confession. The state appellate court reversed the conviction, holding that the finding of cocaine was in the back armrest and Pringle was in the front-seat of a car meaning that it cannot belong to Pringle.

b. Issue: Does an arrest of a

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