Brinegar v. United States
Citation: 338 U.S. 160 (1949)
Facts
Federal liquor agents stopped Brinegar’s car based on their knowledge of his past record for hauling liquor and their observation that his car appeared heavily loaded. They searched the car and found illegal liquor.
Issue
Was there probable cause to stop and search Brinegar’s vehicle?
Holding
Yes. Probable cause exists when the facts known to the officer, together with reasonable inferences drawn from those facts, are sufficient to warrant a prudent person’s belief that the law has been or is being violated. The totality of the officer’s prior knowledge of the defendant, combined with observations at the time, was sufficient.
Rule
Probable cause standard: Probable cause exists when the facts and circumstances known to the officer, together with reasonable inferences therefrom, are sufficient to warrant a person of reasonable caution in the belief that a crime has been or is being committed. It is a practical, nontechnical standard dealing with probabilities — not certainty.
“In dealing with probable cause, as the very name implies, we deal with probabilities. These are not technical; they are the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act.”
Significance
- Foundational statement of the probable cause standard — the “reasonable prudent person” formulation
- Combined with Illinois v. Gates (totality of circumstances): probable cause is assessed holistically, based on all known facts and reasonable inferences
- Distinguished from reasonable suspicion (the lower Terry standard for stops): probable cause requires more — a fair probability, not merely reasonable suspicion
- The quote about “practical considerations of everyday life” is among the most cited in Fourth Amendment law