Wyoming v. Houghton
Headline: Court allows police to search a passenger’s bags found in a car when officers have probable cause to search the vehicle, reversing the state court and narrowing passenger privacy protections.
Holding: When officers have probable cause to search a car for contraband, they may search passengers’ personal belongings inside the car that could conceal the contraband.
- Allows police to search passengers’ bags when they have probable cause to search the car.
- Reduces passenger privacy protections during many traffic stops.
- Limits protection to body searches, excluding container searches in cars.
Summary
Background
A Wyoming Highway Patrol officer stopped a car for traffic violations and saw a syringe in the driver David Young’s pocket. Young admitted using drugs. Officers searched the passenger area and found a purse that Sandra K. Houghton claimed. Inside the purse they found a wallet with her ID, two small containers, syringes, and drug paraphernalia; Houghton was arrested and convicted. The Wyoming Supreme Court reversed, saying passenger belongings were protected unless there was probable cause specific to the passenger’s container.
Reasoning
The national Court examined whether having probable cause to search a car allows officers to inspect containers inside it. Relying on historical practice and prior cases, the Court concluded that if officers have probable cause to believe contraband is in the car, they may search any part of the car and any container that could hide the contraband. The Court distinguished searches of a person (which get greater protection) from searches of property found in a vehicle. It therefore reversed the state court and upheld the search of the purse under the automobile-search rule.
Real world impact
Going forward, police who have probable cause to search a vehicle may also search passengers’ bags or containers that could hide the suspected items. The ruling narrows passenger privacy in many routine traffic stops where officers suspect contraband in the car. The decision leaves limits: it applies to automobile searches and containers in cars and does not authorize searches of a person’s body.
Dissents or concurrances
Justice Breyer joined but emphasized limits: the rule covers only cars and containers and not searches of persons; Justice Stevens (joined by Souter and Ginsburg) dissented, arguing for a warrant or individualized probable cause to protect passenger privacy.
Opinions in this case:
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