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Wyoming v. Houghton


The defendant was one of two female passengers in a lawfully stopped automobile. While the officer was questioning the driver, David Young, he noticed a syringe in Young’s shirt pocket. The officer asked Young to step out of the car and asked why he had a syringe. Young stated the syringe was used to take drugs. The officer entered the automobile in search of contraband. On the back seat of the automobile, he found a purse, which was claimed by the defendant. Inside the purse the officer located a wallet containing her driver’s license, a brown pouch and a black, wallet-type container. The defendant admitted that the black wallet belonged to her but denied ownership of the brown pouch. The officer found contraband in both containers.


Whether an officer is justified in searching passengers’ containers under the mobile conveyance exception to the Fourth Amendment’s warrant requirement?


Yes. The mobile conveyance exception to the Fourth Amendment’s warrant requirement allows the officers to search wherever the items they seek could be located in the mobile conveyance.


The Supreme Court stated that the officer’s probable cause to search the automobile was incontestable. Once the Court found probable cause existed, it limited its discussion to determining the scope of the search. Citing United States v. Ross (1982), the Supreme Court stated that “[I]f probable cause justifies 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.” In the case at hand, the Court held that this includes containers that belong to passengers. In doing so, the Court rejected ownership as a factor to be considered by the officer before conducting an automobile search. While the Court held that the containers of passengers were subject to a search of the mobile conveyance, this same rationale could not be applied to the body of the passengers because of the significantly heightened protection traditionally provided to one’s person.


526 U.S. 295, 119 S. Ct. 1297 (1999)

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