Wyoming v. Houghton (1999)
Overview
Wyoming v. Houghton clarified the scope of vehicle searches under the automobile exception.
During a lawful stop, an officer found a syringe on the driver and searched a passenger’s purse, discovering drugs.
Ruling
The Supreme Court ruled that when officers have probable cause (PC) to search a vehicle, they may search passenger belongings capable of concealing evidence.
Legal Principle Established
“When there is probable cause to search a vehicle, that probable cause extends to all containers within the vehicle that could conceal the object of the search.”
Implication
This decision expanded the automobile exception, allowing officers to search any passenger’s property within reach when PC exists for the vehicle.
Quick Guide
- Probable cause to search a car extends to all passengers and containers.
- Applies to visible contraband, drug investigations, or suspicious activity.
- Officers should articulate specific facts supporting PC in reports.
- Enables lawful searches during RP vehicle scenes involving narcotics or weapons.