Wyoming v. Houghton

In Wyoming v. Houghton, 526 U.S. 295 (1999), an officer stopped a driver for speeding and driving with a faulty brake light. While questioning the driver, the officer noticed a syringe in his shirt pocket. "The officer then asked the driver why he had a syringe; with refreshing candor, the driver replied that he used it to take drugs." Id. at 298. The existence of probable cause went uncontested, and citing Carroll v. United States, 267 U.S. 132 (1925), the Supreme Court recognized such as the starting point for its analysis. Houghton, supra at 300. In Wyoming v. Houghton, the United States Supreme Court held that police officers with probable cause to conduct a warrantless search of an automobile for contraband could search a purse left by a passenger on the back seat of the car. Sandra Houghton was a passenger in a car that was stopped by police for speeding and displaying a faulty brake light. The officer saw a hypodermic syringe in the driver's shirt pocket. The driver admitted that he used the the syringe to "take drugs." Based on the driver's admission, the officer searched the car for contraband. The search included Houghton's purse, which was on the back seat of the car. Houghton's purse contained methamphetamines and drug paraphernalia. The Houghton Court held that police officers with probable cause to search a car may search a passenger's belongings found in the car that could conceal the object of the search. The Court determined that passengers, as well as drivers, "possess a reduced expectation of privacy" in regard to items that they transport in automobiles. The heightened protection afforded to a passenger against a search of his or her person does not apply to a search of the passenger's personal property found inside an automobile. The important issue is the location of the container within the automobile, not the ownership of the container. The Houghton Court reasoned that three factors favored allowing the search of a passenger's belongings: the risk of losing evidence due to the mobility of an automobile, the possibility that a passenger may be engaged with the driver in a common criminal endeavor and have a personal interest in concealing contraband, and the chance that a passenger may become an "unwitting accomplice" to the driver's crime if the driver has sought to hide evidence in a passenger's belongings. The United States Supreme Court held that probable cause to search a vehicle includes probable cause to search closed containers left in the car by passengers. There, police officers stopped a vehicle for traffic violations. Two passengers were in the car and one, David Young, had a hypodermic syringe in his pocket. One officer asked Young why he had a syringe in his pocket: "with refreshing candor, Young replied that he used it to take drugs." ( Id. at p. 298.) At this point the officers ordered both passengers out of the car. In light of Young's admission, the car was searched, including the purse of the other passenger, Houghton, which had been left on the rear passenger seat. In the purse was found drug paraphernalia and a syringe which contained methamphetamine. She was arrested and felony charges were filed. A motion to suppress the contraband was denied and Houghton was convicted as charged. The Wyoming Supreme Court reversed the conviction concluding that probable cause to search the car did not extend to a search of Houghton's purse.