Wyoming v. Houghton Case Brief

Why is the case important?

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.

Facts of the case

After pulling Sandra Houghton’s friend over during a routine traffic stop, a Wyoming Highway Patrol officer noticed a needle in the driver’s shirt pocket. Upon learning that the needle was used for drugs, the officer searched the car and Houghton’s purse, where he found more drug paraphernalia. Houghton challenged her subsequent arrest on drug charges, alleging that the officer’s search of her purse was unconstitutional. On appeal from an adverse appeals court ruling, overturning a favorable trial court decision, the Supreme Court granted Wyoming certiorari.

Question

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?

Answer

Yes. Reverse the judgment of the Wyoming Supreme Court.
Police officers with probable cause to conduct a warrantless search of a car for contraband are still in compliance with the Fourth Amendment if they search a passenger’s belongings capable of concealing contraband.

Conclusion

The Court reversed the order that reversed appellee’s conviction because the police officers had probable cause to search the car appellee was riding in, and, therefore, were entitled to inspect appellee’s belongings found in the car that were capable of concealing the object of the search. The  Court held that the officer was entitled to inspect appellee’s belongings found in the car that were capable of concealing the object of the search because he had probable cause to search the car.

  • Case Brief: 1999
  • Petitioner: Wyoming
  • Respondent: Houghton
  • Decided by: Rehnquist Court

Citation: 526 US 295 (1999)
Argued: Jan 12, 1999
Decided: Apr 5, 1999