WYOMING V. HOUGHTON
526 U.S. 295 (1999)
NATURE OF THE CASE: This was a dispute over searches incident to a traffic stop with
evidence of drug paraphernalia in plain view.
FACTS: Police stopped a car for speeding and a broken brake light. During the stop, the
police noticed that the driver had a syringe in his shirt pocket. The driver admitted to
using the syringe for drug usage. The other female occupants of the car were then ordered
out of the car while the car was searched for contraband. Sandra Houghton (D) initially gave
a false name but her purse, found in the back of the car, was eventually searched and her
I.D. as well as drug paraphernalia, and a syringe with 60 ccs of methamphetamine and another
with 10 ccs of meth. Fresh needle tracks were also found on D's arms. D was arrested tried
and convicted. D's motion to suppress was denied. The Supreme Court of Wyoming reversed the
conviction and held that the search of D's purse violated the Fourth Amendment; the officers
should have known that the purse did not belong to the driver but one of the passengers and
that there was no probable cause to search the passenger's belongings as they had no reason
to believe that there was contraband in the purse. The Supreme Court granted certiorari.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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