Wyoming v. Houghton

Wyoming v. Houghton, 526 U.S. 295 (1999), is a United States Supreme Court case which held that absent exigency, the warrantless search of a passenger's container capable of holding the object of a search for which there is probable cause is not a violation of the Fourth Amendment to the United States Constitution, because it is justified under the automobile exception as an effect of the car.[1]

Wyoming v. Houghton
Supreme Court of the United States
Argued January 12, 1999 Decided April 5, 1999
Full case name	Wyoming, Petitioner v. Sandra K. Houghton
Citations	526 U.S. 295 (more) 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
Case history
Prior	956 P.2d 363 (Wyo. 1998); cert. granted, 524 U.S. 983 (1998).
Holding
Absent exigency, the warrantless search of a passenger's container capable of holding the object of a search for which there is probable cause is not a violation of the Fourth Amendment, justified under the automobile exception as an effect of the car.
Court membership
Chief Justice William Rehnquist Associate Justices John P. Stevens · Sandra Day O'Connor Antonin Scalia · Anthony Kennedy David Souter · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer
Case opinions
Majority	Scalia, joined by Rehnquist, O'Connor, Kennedy, Thomas, Breyer
Concurrence	Breyer
Dissent	Stevens, joined by Souter, Ginsburg
Laws applied
U.S. Const. amend. IV

Background

In Houghton, the Supreme Court was confronted with the question of whether the scope of a vehicle exception search included a passenger's purse. The car had been stopped by a police officer for a faulty brake light, and the driver was promptly observed to have a syringe in his shirt pocket. He admitted he used it to shoot up. A backup police car soon arrived, and the passengers were ordered out of the car. Ms. Houghton gave a false name. While looking through her purse, an officer found her driver's license and, thus, her real name. Continuing the search, the officer found a syringe with 60 ccs of methamphetamine. Looking at her arms, he saw fresh needle tracks. She was arrested.[2]

The trial court denied her motion to suppress and she was convicted. On appeal, the Wyoming Supreme Court reversed because the officers lacked probable cause to search her purse simply based on the driver's possession of a syringe.[3]

Opinion of the Court

The Supreme Court reversed, 6–3. Justice Scalia, writing for the majority, stated that all Fourth Amendment inquiries look first to the intent of the Framers of the Constitution. If that does not provide an answer, then "we must evaluate the search or seizure under traditional standards of reasonableness by assessing, on the one hand, the degree to which it intrudes upon an individual's privacy and, on the other, the degree to which it is needed for the promotion of legitimate governmental interests."

Looking to Carroll v. United States,[4] the first automobile exception case from 1925, the Court found there that the Framers would hold that the whole car could be searched if there was probable cause to believe it contained contraband. Likewise, the Court opined in United States v. Ross[5] that the Carroll doctrine permitted searches of all containers found in a vehicle there was probable cause to search.[6]

Going one step further, however, the Court held that even if the historical perspective was not enough, a "balancing of the relative interests weigh decidedly in favor of allowing searches of passenger's belongings" because of the reduced expectation of privacy in and the mobility of automobiles. Also, passengers in cars are more likely engaged in a common enterprise with the driver and "have the same interest in concealing the fruits or the evidence of their wrongdoing." Also, their proximity enables them "to hide contraband in [each other's] belongings as readily as in other containers in the car ... perhaps even surreptitiously, without the passenger's knowledge or permission." While these factors will not always be present, "the balancing of interests must be conducted with an eye to the generality of cases." Thus, specific probable cause to the container was not required.

Dissent

Justice Stevens, the author of Ross, dissented with Justices Souter and Ginsburg. He found that precedent did not dictate the result, and he noted that Ross "categorically rejected the notion that the scope of a warrantless search of a vehicle might be 'defined by the nature of the container in which the contraband is secreted. ... Rather, it is defined by the object of the search and the places in which there is probable cause to believe that it may be found.'" Since there was no dispute there was no probable cause to believe that Houghton's purse contained contraband, the search should have been suppressed.

The dissenters also disagreed with an effective presumption that persons in a vehicle would be holding each other's evidence or contraband.

Finally, the dissenters disagreed with elevating law enforcement interests over privacy concerns and that the "two-step Fourth Amendment approach wherein the privacy and governmental interests at stake must be considered only if 18th-century common law 'yields no answer'" because nothing cited by the Court mandated that approach and the Court did address the contemporary privacy interests involved. Indeed, United States v. Di Re[7] dictated that Carroll did not permit a search of a passenger where there was no probable cause.

See also

• Arkansas v. Sanders, 442 U.S. 753 (1979)
• California v. Greenwood, 486 U.S. 35 (1988)
• Carroll v. United States (1925)

References

1. Wyoming v. Houghton, 526 U.S. 295 (1999).  This article incorporates public domain material from this U.S government document.
2. In her purse, there were two separate containers in which drugs and drug paraphernalia were found. She disclaimed any ownership interest in one of them.
3. Houghton v. State, 956 P.2d 363 (Wyo. 1998).
4. Carroll v. United States, 267 U.S. 132 (1925).
5. United States v. Ross, 456 U.S. 798 (1982).
6. Houghton, 143 L.Ed.2d at 415, quoting Ross, 456 U.S. at 820 n. 26:

   It is noteworthy that the early legislation on which the Court relied in Carroll concerned the enforcement of laws imposing duties on imported merchandise... . Presumably such merchandise was shipped then in containers of various kinds, just as it is today. Since Congress had authorized warrantless searches of vessels and beasts for imported merchandise, it is inconceivable that it intended a customs officer to obtain a warrant for every package discovered during the search; certainly Congress intended customs officers to open shipping containers when necessary and not merely to examine the exterior of cartons or boxes in which smuggled goods might be concealed. During virtually the entire history of our country--whether contraband was transported in a horse-drawn carriage, a 1921 roadster, or a modern automobile--it has been assumed that a lawful search of a vehicle would include a search of any container that might conceal the object of the search.

7. United States v. Di Re, 332 U.S. 581 (1948).

External links

• Text of Wyoming v. Houghton, 526 U.S. 295 (1999) is available from:  Cornell  CourtListener  Google Scholar  Justia  Library of Congress  Oyez (oral argument audio)