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Wyoming
v. Houghton:
United States Supreme
Court, 1999.
Statement of the Case:
Wyoming is appealing a suppression of
evidence when they charged the ? with felony methamphetamine
possession but was ruled to have violated the 4th amendment when
they searched the ?’s, a passenger’s, purse without a
warrant.
Procedure:
Trial court denied the motion to suppress,
appellate court affirmed, and WY supreme court reversed for ?.
Facts:
Driver was pulled over on suspicion
drugs were in the car. Purse was left on seat of the
car. ? claimed that purse was hers, and it turned out her
ID showed she lied about her name. Further inspection of purse
showed drugs in it. There was probable cause to stop and
search car, but no search warrant was issued.
Issue:
Whether a search of a purse found inside a
car violated the 4th Amendment when the search was of
a passenger’s belongings inside a car where there was
probable cause to believe the car contained contraband.
Procedural Result:
Reversed for State.
Holding:
A search of a purse found inside a car
DOES NOT violate the 4th Amendment when the search was
of a passenger’s belongings inside a car where there was
probable cause to believe the car contained contraband.
Reasoning:
- Police had probable
cause drugs were in the car.
- During whole
history of America, it was assumed that a lawful search
of a vehicle included a search of any container that
might conceal the object of the search.
- Ross Rule:
If probable cause justifies the search of a lawfully
stopped vehicle, it justifies the search of every part of
the vehicle and its contents that may conceal the object
of the search.
- Applies
broadly, regardless to ownership of the
container.
- Rule:
Passengers, no less than drivers, possess a reduced
expectation of privacy with regard to the property that
they transport in cars, which travel public
thoroughfares.
Concurring:
- Rule only applies
to automobile searches.
- Does not extend to
searches of the people found in the vehicle.
Additional Points:
- Houghton:
- Probable
cause to search a car does not justify a body
search of a passenger.
- Probable
cause to search is a necessary predicate for
application of the automobile doctrine.
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