In Rakas v. Illinois, 439 U.S. 128, 58 L. Ed. 2d 387, 99 S. Ct. 421 (1978), the leading authority on passenger standing, the passengers did not contest the validity of the stop, and the Supreme Court resolved their search objection by concluding that they had shown no "legitimate expectation of privacy in the glove compartment or area under the seat of the car in which they were merely passengers." Id. at 148. The Fourth Amendment guarantees "the right of the people to be secure in their persons, houses, papers and effects, against unreasonable search and seizures." A protected Fourth Amendment interest requires an individual's "legitimate expectation of privacy in the invaded place." In Rakas, the Supreme Court concluded that the traditional "standing requirement . . . is more properly subsumed under substantive Fourth Amendment doctrine." 439 U.S. at 139. Although the Court acknowledged "the inquiry under either approach is the same," it stated "the better analysis forthrightly focuses on the extent of a particular defendant's rights under the Fourth Amendment, rather than on any theoretically separate, but invariably intertwined concept of standing." Id.