Wyoming v. Houghton
| Wyoming v. Houghton | |
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| Argued January 12, 1999 Decided April 5, 1999 |
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| 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
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| Prior history | 956 P. 2d 363 (Wyo. 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 | |
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| 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 | |
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.
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.
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.
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.
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