Wyoming v. Houghton
Citation: 526 U.S. 295 (1999)
Facts
Police stopped a car for a traffic violation and found drug paraphernalia on the driver. They searched the car and found Houghton’s purse on the back seat, which contained methamphetamine. The probable cause was for drug activity by the driver; the purse belonged to a passenger.
Issue
When police have probable cause to search a vehicle for contraband, may they search a passenger’s belongings found in the vehicle?
Holding
Yes. When officers have probable cause to search a vehicle for contraband, they may search all containers in the vehicle that could contain the contraband — including containers belonging to passengers — without needing particularized suspicion as to the passenger.
Rule
Automobile exception — passenger belongings: Police officers with probable cause to search a vehicle may inspect passengers’ belongings found in the vehicle that are capable of concealing the contraband. The passenger’s ownership of the container does not require additional particularized suspicion.
Significance
- Extends the automobile exception’s container rule (Ross, Acevedo) to passenger property
- Rationale: probable cause to search a vehicle attaches to the vehicle as a whole; a passenger’s container could conceal the contraband just as readily as the driver’s
- Distinguished from Ybarra v. Illinois (mere propinquity to a searched person/place does not justify searching a bystander — but there, the search authority was a warrant for a tavern, not an automobile exception case)
- Police may search but cannot seize and remove a passenger’s property without probable cause specific to that person