What did Wyoming v Houghton establish about the search of a passenger's container?

Wyoming v. Houghton established that the search of a passenger's container is justified under the automobile exception to the Fourth Amendment's warrant requirement. The case clarified that when an officer has probable cause to search a vehicle, they can search containers within that vehicle without needing a warrant, even if the containers belong to a passenger. This ruling is based on the principle that vehicles are inherently mobile and can be driven away, which creates a distinct scenario where the need for prompt action is essential.

By applying the automobile exception, the court recognized that the presence of passenger containers in a vehicle does not diminish the officer's authority to search that vehicle if the criteria for probable cause are met. The decision is significant in allowing law enforcement greater flexibility in the field, while still providing a framework for protecting individual rights under the Fourth Amendment.