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Court Opinions ›› Wyoming v. Houghton (1999)
WYOMING, PETITIONER v. SANDRA HOUGHTON
No. 98-184 SUPREME COURT OF THE UNITED STATES 526 U.S. 295; 119 S. Ct. 1297; 143 L. Ed. 2d 408; 1999 U.S. LEXIS 2347; 67 U.S.L.W. 4225; 99 Cal. Daily Op. Service 2476; 99 Daily Journal DAR 3230; 1999 Colo. J. C.A.R. 1924; 12 Fla. L. Weekly Fed. S 179 January 12, 1999, Argued April 5, 1999, Decided PRIOR HISTORY: ON WRIT OF CERTIORARI TO THE SUPREME COURT OF WYOMING. During a routine traffic stop, a Wyoming Highway Patrol officer noticed a hypodermic syringe in the driver's shirt pocket, which the driver admitted using to take drugs. The officer then searched the passenger compartment for contraband, removing and searching what respondent, a passenger in the car, claimed was her purse. He found drug paraphernalia there and arrested respondent on drug charges. The trial court denied her motion to suppress all evidence from the purse as the fruit of an unlawful search, holding that the officer had probable cause to search the car for contraband, and, by extension, any containers therein that could hold such contraband. Respondent was convicted. In reversing, the Wyoming Supreme Court ruled that an officer with probable cause to search a vehicle may search all containers that might conceal the object of the search; but, if the officer knows or should know that a container belongs to a passenger who is not suspected of criminal activity, then the container is outside the scope of the search unless someone had the opportunity to conceal contraband within it to avoid detection. Applying that rule here, the court concluded that the search violated the Fourth and Fourteenth Amendments.
Police officers with probable cause to search a car, as in this case, may inspect passengers' belongings found in the car that are capable of concealing the object of the search.
Today, instead of adhering to the settled distinction between drivers and passengers, the Court fashions a new rule that is based on a distinction between property contained in clothing worn by a passenger and property contained in a passenger's briefcase or purse.
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