In the case of Maryland v. Joseph Jermaine Pringle, the U.S. Supreme Court ruled in 2003 that police officers had probable cause to arrest all occupants of a car when they discovered drugs inside it and none of the occupants admitted ownership or knowledge of them. The court held that under these circumstances, it was reasonable for an officer to believe there was probable cause because any or all three men could have been aware and had control over the cocaine found in the vehicle. This decision overturned a previous ruling by Maryland's highest court which stated that finding contraband in a car does not automatically give police grounds to arrest everyone inside unless there is other evidence linking them to criminal activity.

In the dissenting opinion for Maryland v. Pringle, Justice John Paul Stevens argued that the arrest of Joseph Jermaine Pringle was unconstitutional due to lack of probable cause. He contended that mere presence in a car where drugs are found does not automatically make all occupants guilty or suspicious enough for an arrest without further evidence linking them to criminal activity. Stevens emphasized that there were no specific facts indicating Pringle's involvement with the cocaine discovered in the vehicle other than his proximity to it, which is insufficient grounds for suspicion under Fourth Amendment standards. The majority's decision, he believed, could potentially lead to unjust arrests and detentions based on guilt by association rather than concrete proof of wrongdoing.