Wyoming v. Houghton Case Brief

Wyoming v. Houghton, 526 U.S. 295, 119 S.Ct. 1297 (1999)

FACTS: On July 23, 1995, a Wyoming Highway Patrol officer stopped a car, with a male driver and two female passengers in the front seat, for minor traffic violations. While questioning the driver, the officer noticed a syringe in his front shirt pocket. He asked the driver to get out and place the syringe on the car. When asked why he had the syringe, the driver with “refreshing candor,” replied he used drugs.

At that point, the two female passengers were instructed to get out of the car and asked for identification. Houghton gave her name, falsely, as “Sandra James” and said she had no ID. During this time, another officer searching the car found a woman’s purse, which Houghton stated belonged to her. He searched the purse and found identification that correctly identified Houghton, as well as two small cases. One case, a black wallet, Houghton claimed as hers, the other, a brown pouch, she claimed was not her property. The first case contained a small amount of liquid methamphetamine, with syringes, not enough for a felony in Wyoming. The brown pouch contained the same, but with enough methamphetamine to support the felony conviction at issue.

Houghton appealed her conviction on the basis that the officer knew the purse did not belong to the male driver, who was the only person arrested at the time the purse was searched. The Wyoming Supreme Court reversed her conviction.

ISSUE: Was the search of the purse constitutional?

HOLDING: Yes

DISCUSSION: Based upon a historical reading of the law, the Court stated that allowing vehicles to be searched for contraband upon probable cause implies that the containers inside the vehicles were also subject to search. Previous cases had not distinguished actual ownership of the particular item as important. “A passenger’s personal belongings, just like the driver’s belongings or containers attached to the car like a glove compartment, are ‘in’ the car, and the officer has probable cause to search for contraband in the car.” (emphasis in original).

In conclusion, the Court stated that “police officers with probable cause to search a car may inspect passengers’ belongings found in the car that are capable of concealing the object of the search.”