Wyoming v. Houghton Case Brief

Citation 

Wyoming v. Houghton, 526 U.S. 295 (1999)

Facts 

During a routine traffic stop, a police officer took note of the presence of a syringe in the driver’s pocket. Upon further search, the officer came upon a purse that had two containers, both with methamphetamine. The evidence obtained after the search was admitted at trial, leading to the conviction of the respondent. Wyoming Supreme Court reversed the ruling, holding that the officer involved in the search did not have a probable cause to search the containers. However, the Fourth Amendment provides that if an officer is aware that the container belongs to an individual that is not suspected of any form of criminal activity, the seized items should not be allowed unless the individual had the opportunity to conceal contraband.

Issue 

When likely cause exists to do a search for contraband goods without a warrant in an individual’s car, is it acceptable under the Fourth Amendment for law enforcement officers to search the packages or the containers in the vehicle without having probable cause?

Holding 

Wyoming Supreme Court ruled in favor of the respondent.

Rationale 

Police officers that have a probable cause for conducting a search of a car for contraband without a warrant still comply with the Fourth Amendment if they search the belongings of passengers that can conceal contraband.

Dissent 

Justice John Paul made it clear to indicate that the effective enforcement of the law did not trump the privacy issues of the case. Conversely, Justice Stephen Breyer made further clarifications that the Fourth Amendment required a warrant of searching a passenger’s purse, and should not apply to automobile searches but also the people in the automobiles.

Impact 

The notice of ownership provision as held by Wyoming Supreme Court was a test to ensure the creation of clear procedures for enforcing the law, and as a result, subjecting them to a situation where they would make difficult decisions as to the determination the owner of the container. An individual can conceal contraband in another person’s container, which was a central provision of having the results of this case come out as it did.