Wyoming V. Houghton - Opinion of The Court

Opinion of The Court

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.

Looking to Carroll v. United States, the first automobile exception case from 1925, the Court found there that the Framers would hold that the whole car could be searched if there was probable cause to believe it contained contraband. Likewise, the Court opined in United States v. Ross that the Carroll doctrine permitted searches of all containers found in a vehicle there was probable cause to search.

Going one step further, however, the Court held that even if the historical perspective was not enough, a balancing of the relative interests weigh decidedly in favor of allowing searches of passenger's belongings because of the reduced expectation of privacy in and the mobility of automobiles. Also, passengers in cars are more likely engaged in a common enterprise with the driver and have the same interest in concealing the fruits or the evidence of their wrongdoing. Also, their proximity enables them to hide contraband in belongings as readily as in other containers in the car ... perhaps even surreptitiously, without the passenger's knowledge or permission. While these factors will not always be present, the balancing of interests must be conducted with an eye to the generality of cases. Thus, specific probable cause to the container was not required.