After stopping a vehicle for speeding in an early morning hour, a police officer obtained consent from the owner-operator to search. The officer found $763 in the glove compartment and five small bags containing a controlled substance behind the back-seat armrest. The officer asked all three occupants of the vehicle who owned the drugs and money. When all three denied ownership he placed them under arrest. Ultimately, the defendant admitted to committing the crime.
Whether the officer had probable cause to believe that the defendant committed the
Yes. Based on the totality of the circumstances, the officer established probable cause that a crime had been committed and the defendant was involved in the crime.
The Court held that “[I]t is uncontested in the present case that the officer, upon recovering the five plastic glassine baggies containing suspected cocaine, had probable cause to believe a felony had been committed.” The more difficult issue is whether the officer had probable cause that the defendant committed the crime. The Court has held on several previous occasions that the probable cause is a “practical, nontechnical conception.” See Illinois v. Gates (1983) (quoting Brinegar); see, e.g., Ornelas v. United States (1996); United States v. Sokolow (1989). It is futile to assign a precise definition or attempt to quantify by percentages probable cause as its exactness depends on the totality of the circumstances.
In this case, the defendant was understandably assumed to be involved in criminal activity. He was one of three occupants, out very early in the morning, in a vehicle that contained a large amount of cash and a controlled substance (packaged in a manner to indicate drug dealing), both located where the defendant had easy access, and all three failed to provide information about the ownership of these incriminating items. The Court found it reasonable that all three had knowledge of and exercised control over the controlled substance based on these circumstances. Therefore, the officer had probable cause to arrest any or all of the three, including the defendant.
540 U.S. 366, 124 S. Ct. 795 (2003)