WHEN CAN A PERSON BE ARRESTED WITHOUT AN ARREST WARRANT?
Sometimes the black letter law passed by the legislature is unclear. The legislature can’t anticipate every possible fact scenario when they pass a law, so it lay to the courts to interpret the law and give guidance to what it means. This interpretation is called case law. When the court decides a certain meeting to the law it essentially answers a legal question. Lawyers and other courts then can rely on that ruling when they have a similar issue in their case. The following case answers the question above.
Maryland v. Pringle, 540 U.S. 366 (2003).
This case answers one primary question:
When does an officer have probable cause to arrest someone?
The probable cause standard requires only a “reasonable ground for belief of guilt… and that the belief of guilt must be particularized with respect to the person to be searched or seized.”
This issue in this case is to whether the police officer had probable cause to arrest the respondent in belief that he was the one who committed the crime of possession of cocaine and, therefore, did not violate the respondent’s Fourth Amendment rights.
A warrantless arrest of an individual in a public place for a felony, or a misdemeanor committed in the officer’s presence, is consistent with the Fourth Amendment if the arrest is supported by probable cause. Id. at 370. The Court has stated that the probable cause standard is incapable of a precise decision due to the fact that it deals with probabilities and depends on the totality of circumstances. Id. at 371. The probable cause standard, however, has been materialized to a “reasonable ground for belief of guilt … and that the belief of guilt must be particularized with respect to the person to be searched or seized.” Id. In order to make this determination, the Court examined the events leading up to the arrest, and then decided whether the facts, when viewed “from the standpoint of an objectively reasonable police officer” amounted to probable cause. Id. The Court stated that due to the amount of cash in the glove compartment directly in front of the respondent, and that the cocaine was located in an area that was accessible to all three of the men in the vehicle that it was an entirely reasonable inference that any or all of the occupants had knowledge of, and exercised dominion and control over the cocaine. Id. Due to the events leading up to the arrest, the Court reasoned that a reasonable officer could conclude that there was probable cause to believe that the respondent committed the crime of possession of cocaine, either solely or jointly. Id. at 372.
The Court also stated that the search or seizure of an individual must also be supported by probable cause particularly in respect to that person, and that the requirement cannot be avoided simply by “the fact that coincidentally there exists probable cause to search or seize another or to search the premises where the person may happen to be.” Id. at 373. However, the Court noted that car passengers are often engaged in a common enterprise, and have the “same interest in concealing the fruits or the evidence of their wrongdoing.” Id. Further, it was stated that the quantity of the drugs as well as the cash in the vehicle, surmounted to a high likelihood of drug dealing, which was an enterprise to which the dealer would be unlikely to admit an innocent person that had the potential to furnish evidence against the dealer. Id. In light of the evidence that lead up to the arrest, the Court concluded that the officer had probable cause to believe that Pringle had committed the crime of possession of a controlled substance and his subsequent arrest, therefore, did not violate his Fourth and Fourteenth Amendments. Id. at 374.