Wyoming v. Houghton
526 U.S. 295, 119 S. Ct. 1297, 143 L. Ed.2d 408 (1999)

  • The police pulled over Young’s car for speeding. The policeman noticed that Young had a hypodermic needle in his pocket.
    • Young admitted that he used the needle for drugs.
  • The policeman asked Young and the two passengers (Houghton and someone else) to get out of the car. He searched the car, including Houghton’s purse. Inside the purse he found more drugs. Houghton was arrested.
  • The Trial Court convicted Houghton of drug possession. She appealed.
    • Houghton argued that the police did not have a warrant or probable cause to search her purse, therefore it was unreasonable and a violation of the 4th Amendment.
  • The Wyoming Supreme Court overturned the conviction. The prosecutor appealed.
    • The Wyoming Supreme Court found that the policeman should have known that the purse did not belong to Young and there was no probable cause to search the passengers’ personal items.
  • The US Supreme Court reversed and upheld the conviction.
    • The US Supreme Court found that the policeman had probable cause to believe that there were drugs in the car, based on Young’s comment. That makes the search of the vehicle reasonable.
    • The Court found that, based on United States v. Ross (456 U.S. 798 (1982)), 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.
      • In Ross, Ross was alone in the car, and the package searched belonged to him, but the Court dismissed the distinction.
    • The Court noted that passengers have a reduced expectation of privacy when riding in someone else’s car. In addition, the Court noted that they’d already found that you could search the driver’s packages, so why should there be a different expectation of privacy for the passengers?
    • The Court applied a balancing test and found that the governmental interested in searching the entire car outweighed the minimal invasion of privacy in having your purse rummaged through.
      • Otherwise, a driver with contraband could stuff it in his passenger’s purse and escape being searched. It would be difficult for a policeman to determine exactly who owned a particular package in a car full of people.
  • In a dissent it was argued that the policeman only had evidence implicating the driver. Since the purse clearly did not belong to the driver, there was no individualized suspicion and therefore no probable cause to search the purse.
    • Of course once one person in the car admitted to possessing drugs, there might be probable cause for believing others in the car also have drugs.
      • The police probably could not search a taxi or a bus if they had individualized suspicion on a single passenger.
      • Except for a search incident to lawful arrest (SILA) of course.