Wyoming vs Houghton Case

Wyoming vs. Houghton 526 U.S. 295 (1999) FACTS: On July 23, 1995, Officer Baldwin made a traffic stop for speeding and a faulty brake light. He went up to the car and noticed the driver of the car had a syringe in his pocket. He told the driver to get out of the car and asked what the syringe was for. He told Officer Baldwin that he used it to take drugs. After this the other two passengers were instructed to get out of the car. One of the passengers identified herself as Sandra James. Because the driver said he was using drugs from the syringe, the rest of the car was searched. In the back seat was a purse. Sandra identified the purse as hers and the driver’s license was pulled out. It was found that Sandra James was actually Sandra D. Houghton. She said she lied about her name in case things got bad. In this purse it was found that there was drug paraphernalia and a syringe will 60 cc’s of methamphetamine. She said she did not know how that got there. There was also more drug paraphernalia and a syringe with 10 cc’s of methamphetamine in it that she said was hers. She was placed under arrest. The State of Wyoming charged her with felony possession of methamphetamine in a liquid amount greater than three-tenths of a gram. Her motion to suppress the evidence was denied. The court said that the officer had probable cause to search the rest of the car and any containers in it were justified. She was convicted. The Wyoming Supreme Court reversed and said that the officer may search the rest of the car, but if there is a container that belongs to someone in the car that has not broken the law then they may not search it. QUESTION: Is a search of the passengers belongings justified under the Fourth Amendment as a reasonable search? YES OPINION: Scalia, J. joined by Rehnquist, C.J., O’Connor, J., Kennedy, J., Thomas, J., and Breyer, J. 1. If probable cause justified 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. 2. Every container that is in the car does not have to be individualized 3. Law enforcement has to be able to search everything in the car, because they would be impaired if they could not 4. A lot of the time passengers are engaged in the same things as the driver 5. If officers could not search everything, then the criminal would just stick everything in the passenger’s belongings 6. Judgment of the Wyoming Supreme Court is reversed CONCURRENCE: Breyer, J. 1. The search of the passengers clothing should not be searched in this situation 2. If the purse was on the passenger then it may be considered outer clothing DISSENT: Stevens, J. along with Souter, J., and Ginsburg, J. 1. In U.S. vs. Di Re it was held that there was not an automobile exception to the Fourth Amendment for passengers 2. 3. 4. 5. The search of a passengers purse is an invasion of privacy Just because there is a passenger in the car does not mean that they are partners in crime The policeman needed to have probable cause to search the purse The state’s concern for effective law enforcement does not outweigh the privacy interest in this case