Wyoming v. Houghton

Facts

A highway patrol officer stopped a car for speeding and driving with a faulty brake light. Three passengers were in the front seat of the car: the driver, the driver’s girlfriend, and the Respondent. While questioning the driver, the officer noticed a hypodermic syringe in his shirt pocket. He then went to get gloves from his car, leaving the occupants with two backup officers. When the officer returned, he told the driver to step out of the car and place the syringe on the hood. When asked why he had the syringe, the driver responded that he used it to take drugs. The two backup officers then told the other female passenger and the Respondent to get out of the car and asked them for their identifications. Respondent falsely identified herself under a fake name and stated that she did not have any identification. Because of the driver’s confession, the officer searched the passenger compartment of the car for contraband. In the back seat he found a purse, which the Respondent said was hers. The officer took a wallet out of the purse which contained the Respondent’s driver’s license, identifying her as Sandra Houghton. When the officer inquired as to why she lied, the Respondent said it was in case things went poorly. The officer then continued to search the purse, finding a black wallet and a brown pouch. The Respondent denied that the brown pouch was hers and stated that she did not know how it got in the purse. Inside the pouch was drug paraphernalia and a syringe of meth. The Respondent did claim the black wallet which also contained meth, although it was an amount insufficient to support a felony conviction. The officer also observed fresh needle tracks on the Respondent’s arms. He then placed the Respondent under arrest. The Respondent was charged with felony possession of meth in a liquid amount greater than three-tenths of a gram.