Wyoming V. Shatzer
Wyoming v. Houghton 526 U.S. 295 (1999)
FACTS: After a routine traffic stop, a police officer noticed a hypodermic syringe in the shirt pocket of the car’s driver, which the driver soon admitted was for using drugs. The officer searched the passenger compartment for contraband and came upon a purse, which the respondent, a passenger in the car, claimed was hers. There was drug paraphernalia inside, and the respondent was arrested on drug charges. The evidence was admitted at trial and respondent was convicted. The Wyoming Supreme Court then reversed, holding that an officer with probable cause to search a vehicle may search all containers that might conceal the object of the search, but if the officer knows or should know that the container belongs to a passenger who is not suspected of criminal activity, then the container is not allowed to be searched under the Fourth Amendment unless someone had the opportunity to conceal contraband. The State of Wyoming was then granted certiorari.
ISSUES:
1. Whether a search of a purse found inside a car violated the 4th Amendment when the search was of a passenger’s belongings inside a car where there was probable cause to believe the car contained contraband.
COURT DECISION: Reversed for the State
RATIONALE FOR THE DECIOSION: by Justice Scalia 1. After a hearing, the trial court denied her motion to suppress all evidence obtained from the purse as the fruit of a violation of the Fourth and Fourteenth Amendments. The court held that the officer had probable cause to search the car for contraband, and, by extension, any containers therein that could hold such contraband. 2. Since a passenger’s privacy expectations are diminished, and governmental interests at stake are large, the balancing of Fourth Amendment interests leans toward allowing searches of passengers’ belongings.
CONCURRING OPINIONS: by BREYER, J. 1. The Supreme Court has previously held that if the police have probable cause to
FACTS: After a routine traffic stop, a police officer noticed a hypodermic syringe in the shirt pocket of the car’s driver, which the driver soon admitted was for using drugs. The officer searched the passenger compartment for contraband and came upon a purse, which the respondent, a passenger in the car, claimed was hers. There was drug paraphernalia inside, and the respondent was arrested on drug charges. The evidence was admitted at trial and respondent was convicted. The Wyoming Supreme Court then reversed, holding that an officer with probable cause to search a vehicle may search all containers that might conceal the object of the search, but if the officer knows or should know that the container belongs to a passenger who is not suspected of criminal activity, then the container is not allowed to be searched under the Fourth Amendment unless someone had the opportunity to conceal contraband. The State of Wyoming was then granted certiorari.
ISSUES:
1. Whether a search of a purse found inside a car violated the 4th Amendment when the search was of a passenger’s belongings inside a car where there was probable cause to believe the car contained contraband.
COURT DECISION: Reversed for the State
RATIONALE FOR THE DECIOSION: by Justice Scalia 1. After a hearing, the trial court denied her motion to suppress all evidence obtained from the purse as the fruit of a violation of the Fourth and Fourteenth Amendments. The court held that the officer had probable cause to search the car for contraband, and, by extension, any containers therein that could hold such contraband. 2. Since a passenger’s privacy expectations are diminished, and governmental interests at stake are large, the balancing of Fourth Amendment interests leans toward allowing searches of passengers’ belongings.
CONCURRING OPINIONS: by BREYER, J. 1. The Supreme Court has previously held that if the police have probable cause to