In the case of Wyoming v. Sandra Houghton, 1998, the U.S. Supreme Court ruled that police officers have the right to search a passenger's personal belongings within a vehicle if they believe there is probable cause that the vehicle contains contraband or evidence of criminal activity. The case arose when Wyoming Highway Patrol officers stopped a car for speeding and noticed drug paraphernalia in plain sight inside it. They then searched all items in the car including Sandra Houghton’s purse where they found drugs leading to her arrest on drug charges. She argued this violated her Fourth Amendment rights against unreasonable searches and seizures as there was no reason to suspect she personally was involved in illegal activities just because she was present in a suspicious vehicle. However, by 6-3 decision, Supreme Court held that once probable cause justifies search of a lawfully stopped vehicle, it extends to every part of it before giving an inventory including containers and packages belonging to passengers.

In the dissenting opinion for Wyoming v. Sandra Houghton, Justice Stevens argued that the majority's decision to allow police officers to search a passenger's purse without probable cause was an unjustifiable violation of Fourth Amendment rights. He contended that there is no historical precedent or compelling logic behind this ruling and it contradicts previous court decisions which have consistently held that warrantless searches are per se unreasonable under the Fourth Amendment unless they fall within some established exception. Furthermore, he pointed out that allowing such searches could lead to arbitrary invasions of privacy by law enforcement officials who may not always act in good faith or with reasonable suspicion. The dissent also noted concerns about potential racial profiling and other forms of discrimination in these types of situations.