Probable Cause

Question 1

Maryland v Pringle

Answer 1

In the early hours of August 7, 1999, a Baltimore County Police officer stopped a Nissan Maxima for speeding. The car was occupied by three men: Donte Partlow, the driver and owner, respondent Joseph Jermaine Pringle, the front-seat passenger, and Otis Smith, the back-seat passenger. Upon opening the glove compartment to retrieve the vehicle’s registration, the officer observed a large amount of rolled-up cash. Subsequent consented search of the vehicle led to the discovery of $763 in cash and five glassine baggies of cocaine hidden behind the back-seat armrest, accessible to all three occupants. After all three men denied ownership of the cocaine and cash, they were arrested. Pringle later confessed to owning the cocaine and intended to use it at a party. Despite his confession, Pringle moved to suppress his confession as the fruit of an illegal arrest, arguing the police lacked probable cause.

Issue
The key issue is whether the officer had probable cause to arrest Pringle for possession of cocaine found in the car, despite the drugs being in a shared vehicle and no specific evidence initially linking the drugs to any individual occupant.

Holding
The United States Supreme Court reversed the judgment of the Court of Appeals of Maryland, holding that the officer did have probable cause to arrest Pringle for the possession of cocaine found in the car he was in, given the totality of the circumstances.

Reasoning

Question 2

Spinelli v United States A tip is not good enough

Answer 2

Facts
William Spinelli was convicted under 18 U.S.C. § 1952 for traveling from Illinois to St. Louis, Missouri, with the intention of conducting illegal gambling activities. His conviction was based on evidence obtained through an FBI search, authorized by a warrant issued on the basis of an affidavit. The affidavit claimed that Spinelli was known to be a gambler and associate of gamblers, and was allegedly using two telephones in a specific apartment for bookmaking. This information was partially supported by an FBI surveillance report and further backed by a tip from a confidential informant, who alleged that Spinelli was operating a gambling operation from the apartment.

Issue
The central issue in this case was whether the search warrant issued against Spinelli was constitutionally valid under the Fourth Amendment, which protects against unreasonable searches and seizures. Specifically, the question was whether the affidavit supporting the warrant provided sufficient probable cause, especially considering the reliance on information from a confidential informant.

Holding
The Supreme Court held that the search warrant was invalid. The Court found that the affidavit used to obtain the warrant did not provide sufficient probable cause to justify the search. Consequently, the Court reversed the decision of the Court of Appeals which had upheld Spinelli’s conviction.

Question 3

Illinois v Gates

Answer 3

Respondents Lance and Susan Gates were indicted for violation of state drug laws following a search of their automobile and home, which uncovered marijuana and other contraband.
The search was conducted based on a search warrant issued in response to an anonymous letter received by the police, which alleged that the Gateses were involved in drug trafficking.
The Illinois Supreme Court affirmed the lower courts’ decision to grant the Gateses’ motion to suppress the evidence, finding the affidavit for the search warrant inadequate under the standards set by previous Supreme Court decisions (Aguilar v. Texas and Spinelli v. United States).
The case presented the Supreme Court with the issue of assessing the adequacy of an anonymous tip, corroborated in part by police investigation, to establish probable cause for the issuance of a search warrant.

Issue
The key issue before the Court was whether the Fourth Amendment’s requirement for probable cause to issue a search warrant can be satisfied by an anonymous informant’s tip, partially corroborated by police investigation, and the adequacy of the “two-pronged test” from Aguilar and Spinelli in this context.

Holding
The Supreme Court held that the “two-pronged test” for assessing the credibility of informant tips, as established in Aguilar and Spinelli, should be replaced by a more flexible, totality-of-the-circumstances approach.
This approach allows a magistrate to determine whether there is a fair probability that contraband or evidence of a crime will be found in a particular place, based on all the circumstances set forth in the affidavit, including the veracity and basis of knowledge of persons supplying hearsay information