Citation. Wyo. v. Houghton, 526 U.S. 295, 119 S. Ct. 1297, 143 L. Ed. 2d 408, 1999 U.S. LEXIS 2347, 67 U.S.L.W. 4225, 99 Cal. Daily Op. Service 2476, 99 Daily Journal DAR 3230, 1999 Colo. J. C.A.R. 1924, 12 Fla. L. Weekly Fed. S 179 (U.S. Apr. 5, 1999)
Brief Fact Summary. The driver of car stopped by police had a syringe in his pocket which he admitted was his. The police then searched the car, finding a purse which the respondent passenger claimed was hers that held two containers, both containing methamphetamine.
Synopsis of Rule of Law. When there is probable cause to search for contraband in a car, it is reasonable under the Fourth Amendment for police officers to examine packages and containers inside without an individualized showing of probable cause for each one.
After a routine traffic stop, a police officer noticed a hypodermic syringe in the shirt pocket of the car’s driver, which the driver soon admitted was for using drugs. The officer searched the passenger compartment for contraband and came upon a purse, which the respondent, a passenger in the car, claimed was hers. There was drug paraphernalia inside, and the respondent was arrested on drug charges. The evidence was admitted at trial and respondent was convicted. The Wyoming Supreme Court then reversed, holding that an officer with probable cause to search a vehicle may search all containers that might conceal the object of the search, but if the officer knows or should know that the container belongs to a passenger who is not suspected of criminal activity, then the container is not allowed to be searched under the Fourth Amendment unless someone had the opportunity to conceal contraband. The State of Wyoming was then granted certiorari. Issue.
When probable cause is present to make a warrantless search for contraband in a car, is it reasonable under the Fourth Amendment for police officers to examine packages and containers therein without an individualized showing of probable cause?