Wyoming v. Houghton

After stopping a car for speeding, an officer saw a syringe in the driver's pocket, and the driver admitted using it for drugs. The officer then searched the passenger compartment and found a purse belonging to passenger Houghton (defendant), which contained methamphetamine she claimed wasn't hers. Houghton was convicted after her suppression motion was denied. The Wyoming Supreme Court reversed, holding officers may not search a passenger's container absent some indication the passenger participated in criminal activity, and the U.S. Supreme Court granted certiorari.

Whether an officer may search containers belonging to a passenger in a car when there is probable cause to search the car.