Maryland Code
Md. Code Ann., Crim. Proc. § 2-202 (2026)
§ 2-202
✓ current as of May 2026
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§2–202.
(a) A police officer may arrest without a warrant a person who commits or attempts to commit a felony or misdemeanor in the presence or within the view of the police officer.
(b) A police officer who has probable cause to believe that a felony or misdemeanor is being committed in the presence or within the view of the police officer may arrest without a warrant any person whom the police officer reasonably believes to have committed the crime.
(c) A police officer without a warrant may arrest a person if the police officer has probable cause to believe that a felony has been committed or attempted and the person has committed or attempted to commit the felony whether or not in the presence or within the view of the police officer.
(a) A police officer may arrest without a warrant a person who commits or attempts to commit a felony or misdemeanor in the presence or within the view of the police officer.
(b) A police officer who has probable cause to believe that a felony or misdemeanor is being committed in the presence or within the view of the police officer may arrest without a warrant any person whom the police officer reasonably believes to have committed the crime.
(c) A police officer without a warrant may arrest a person if the police officer has probable cause to believe that a felony has been committed or attempted and the person has committed or attempted to commit the felony whether or not in the presence or within the view of the police officer.
Notes of Decisions
Cited in 32
cases (7 in the last 5 years), 2002–2025 · leading case: State v. Wallace, 812 A.2d 291 (Md. 2002).
State v. Wallace, 812 A.2d 291 (Md. 2002). “A police officer may arrest without a warrant a person who commits or attempts to commit a felony or misdemeanor in the presence or within the view of a police officer. (b) Probable cause to believe crime committed in the presence of officer.”
Motor Veh. Admin. v. Shepard, 923 A.2d 100 (Md. 2007). “[3] See Maryland Code (2001), § 2-202(a) of the Criminal Procedure Article.”
Cotton v. State, 872 A.2d 87 (Md. 2005). “A police officer may arrest without a warrant a person who commits or attempts to commit a felony or misdemeanor in the presence or within the view of the police officer. (b) Probable cause to believe a crime committed in presence of officer.”
Sizer v. State, 174 A.3d 326 (Md. 2017). “), § 2-202(a) of the Criminal Procedure Article.”
Pringle v. State, 805 A.2d 1016 (Md. 2002). “(b) Arrest for crime apparently committed in presence of officer.”
Haley v. State, 919 A.2d 1200 (Md. 2007). “), § 2-202 of the Criminal Procedure Article; Swift, 393 Md.”
Evans v. State, 922 A.2d 620 (Md. Ct. Spec. App. 2007). “Warrantless arrests are generally covered in § 2-202 of the Criminal Procedure Article, which provides: (a) A police officer may arrest without a warrant a person who commits or attempts to commit a felony or misdemean- or in the presence or within the view of the police officer.”
Massey v. State, 917 A.2d 1175 (Md. Ct. Spec. App. 2007). “Md.Code Ann., Crim. Proc. § 2-202 (2001), governs warrantless arrests, and provides, in part: § 2-202.”
Whitley v. Maryland State Bd. of Elections, 55 A.3d 37 (Md. 2012). “), § 2-202 of the Criminal Procedure Article.”
Barrett v. State, 174 A.3d 441 (Md. Ct. Spec. App. 2017). “), § 2-202(b) of the Criminal Procedure Article (providing that “[a] police officer who has probable cause to believe that a felony or misdemeanor is being committed in the presence or within the view of the police officer may arrest without a warrant any person whom the police…”
Faulkner v. State, 847 A.2d 1216 (Md. Ct. Spec. App. 2004). “Code (2001), § 2-202 of the Criminal Procedure Article.”
McDaniel v. Arnold, 898 F. Supp. 2d 809 (D. Md. 2012). “), § 2-202(b) of the Criminal Procedure Article (granting legal authority to “police officer who has probable cause to believe that a felony or misdemeanor is being committed in the presence or within the view of the police officer [to] arrest without a warrant any person whom…”
Md. Code Ann., Crim. Proc. § 2-202(a): 5 cases
Motor Veh. Admin. v. Shepard, 923 A.2d 100 (Md. 2007). “[3] See Maryland Code (2001), § 2-202(a) of the Criminal Procedure Article.”
Sizer v. State, 174 A.3d 326 (Md. 2017). “), § 2-202(a) of the Criminal Procedure Article.”
United States v. Atwell, 470 F. Supp. 2d 554 (D. Md. 2007).
McCullough v. Anne Arundel Cnty., Maryland, No. 1:19-cv-00926 (D. Md. Feb. 20, 2020).
Brathwaite v. Georgiades, No. 1:23-cv-00277 (D. Md. Dec. 12, 2024).
Md. Code Ann., Crim. Proc. § 2-202(b): 8 cases
Barrett v. State, 174 A.3d 441 (Md. Ct. Spec. App. 2017). “), § 2-202(b) of the Criminal Procedure Article (providing that “[a] police officer who has probable cause to believe that a felony or misdemeanor is being committed in the presence or within the view of the police officer may arrest without a warrant any person whom the police…”
McDaniel v. Arnold, 898 F. Supp. 2d 809 (D. Md. 2012). “), § 2-202(b) of the Criminal Procedure Article (granting legal authority to “police officer who has probable cause to believe that a felony or misdemeanor is being committed in the presence or within the view of the police officer [to] arrest without a warrant any person whom…”
Williams v. State, 981 A.2d 46 (Md. Ct. Spec. App. 2009).
Belote v. State, 20 A.3d 143 (Md. Ct. Spec. App. 2011).
Swagler v. Sheridan, 837 F. Supp. 2d 509 (D. Md. 2011).
Md. Code Ann., Crim. Proc. § 2-202(c): 2 cases
State v. Rowlett, 859 A.2d 303 (Md. Ct. Spec. App. 2004).
Shuler v. State, No. 2257/23 (Md. Ct. Spec. App. Oct. 31, 2025).
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