Near 3 a.m. on August 7, 1999, a police officer in Baltimore County, Maryland pulled over a car for speeding and for the driver's failure to wear a seatbelt.

The car was being driven by Donte Partlow, the vehicle's owner, and had two passengers: Joseph Pringle in the front seat, and Otis Smith in the backseat.

Upon searching, the officers found cocaine behind the backseat armrest, as well as $763 in cash in the glove compartment.

The Maryland Court of Special Appeals affirmed, but the Maryland Court of Appeals reversed, holding that, absent specific facts tending to show Pringle's knowledge and dominion or control over the drugs, the mere finding of cocaine in the back armrest when Pringle was a front-seat passenger in a car being driven by its owner was insufficient to establish probable cause for an arrest for possession of drugs.

To determine whether an officer had probable cause to make an arrest, a court must examine the events leading up to the arrest, and then decide "whether these historical facts, viewed from the standpoint of an objectively reasonable police officer, amount to" probable cause.