Wyoming v. Houghton
Case Date: 07/09/1999
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Wyoming v. Houghton, 526 U.S. 295 (1999), was a decision by the United States Supreme Court, which held that, absent exigency, the warrantless search of a passenger's container capable of holding the object of a search for which there is probable cause is a violation of the Fourth Amendment, but justified under the automobile exception as an effect of the car.
The Court was confronted with the question of whether the scope of a vehicle exception search included a passenger's purse. The car was stopped for a faulty brake light, and the driver was promptly observed to have a syringe in his shirt pocket. He admitted he used it to shoot up. Backup arrived, and the passengers were ordered out of the car. Ms. Houghton gave a false name. While looking through her purse, an officer found her driver's license and, thus, her real name. Continuing the search, the officer found a syringe with 60 ccs of methamphetamine. Looking at her arms, he saw fresh needle tracks. She was arrested.[1]
The trial court denied her motion to suppress and she was convicted. On appeal, the Wyoming Supreme Court reversed because the officers lacked probable cause to search her purse simply based on the driver's possession of a syringe.
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