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(quoting Longshore v. State, 399 Md. 486, 501 (2007) (quotations and alterations omitted)).
As Judge Hollander explained in State v. Cabral, 159 Md. App. 354 (2004),
Probable cause requires “less evidence for such belief than would justify
conviction but more evidence than that which would arouse a mere
suspicion.” Carroll v. State, 335 Md. 723, 735 (1994). Moreover, it is
assessed by considering “the totality of the circumstances in a given
situation . . . .” Collins v. State, 322 Md. 675, 680 (1991).
In determining whether a search [or seizure] was founded on probable
cause, hyper-technical analysis, divorced from the realities of everyday life,
is not required. See Potts v. State, 300 Md. 567, 573 (1984). As the Supreme
Court explained in Brinegar v. United States, 338 U.S. 160, 175–76 (1949):
“In dealing with probable cause . . . , as the 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.” See Illinois v. Gates, 462 U.S. 213, 231 (1983)
(reiterating that “the central teaching of [its] decisions bearing on the
probable-cause standard is that it is a ‘practical, nontechnical conception.’”
(quoting Brinegar, 338 U.S. at 176)).
Id. at 374 (some citations omitted). The probable-cause standard is “incapable of precise
definition or quantification into percentages,” Maryland v. Pringle, 540 U.S. 366, 371
(2003), but “[t]he substance of all the definitions of probable cause is a reasonable ground
for belief of guilt,” Brinegar, 338 U.S. at 175 (cleaned up). That belief of guilt “must be
particularized with respect to the person to be searched or seized.” Pringle, 540 U.S. at
371.
To argue that police lacked probable cause for Eusebio’s arrest and search, Eusebio
points us to DeAngelo, 199 Md. 48, discussed above. In that case, DeAngelo walked into
another man’s home while police were executing a warrant to search the place for evidence
of an illegal lottery operation. DeAngelo, 199 Md. at 49–50. Police had never seen
DeAngelo before, and they conceded he was not violating any law in their presence. Id. at