Supreme Court of the United States · 1999 · Criminal Procedure
Criminal ProcedureFourth Amendmentautomobile exceptionpassenger belongingscontainerFourth Amendmentautomobile exceptionprobable cause
Facts
Police had probable cause to search a car for drugs. During that search, an officer searched a purse found inside the car and discovered the owner’s identification while looking through it. The purse was at a considerable distance from its owner, and she did not claim ownership until the officer found her identification. The search concerned a container located in the automobile, not a search of her person.
Issue
When police have probable cause to search an automobile for drugs, may they also search a container found inside the car without first establishing whether it belongs to a passenger? Relatedly, what limits apply to that rule when the container is a purse or is closely associated with a person?
Rule
If police have probable cause to search a car for drugs, it is reasonable for them to search containers within the car without first establishing the container’s ownership. This bright-line rule applies only to automobile searches and only to containers found within automobiles; it does not extend to the search of a person, and a container attached to the person may receive heightened protection.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Tulsa, an officer stops a sedan after seeing drug paraphernalia in plain view and smelling burnt methamphetamine residue, giving the officer probable cause to search the car for drugs. On the rear floorboard, the officer finds a zippered canvas tote, and passenger Elena Ruiz immediately says, "That's my bag."
May the officer search the tote without first resolving whether it belongs to Elena rather than the driver?
Explanation. When officers have probable cause to search an automobile for drugs, they may search containers found within the car without first establishing who owns them. The rule is designed as a bright-line rule; requiring officers to sort out ownership claims would undermine its workability. A passenger's statement that the container is hers does not itself bar the search so long as the item is a container within the automobile rather than part of her person. (Derived from Wyoming v. Houghton (1999).)