Wyoming v. Houghton, 526 U.S. 295 (1999), is a United States Supreme Court case which held that absent exigency, the warrantless search of a passenger's container capable of holding the object of a search for which there is probable cause is not a violation of the Fourth Amendment to the United States Constitution because it is justified under the automobile exception as an effect of the car.

Looking to Carroll v. United States,[4] the first automobile exception case from 1925, the court found there that the framers would hold that the entire car could be searched if there was probable cause to believe that it contained contraband.

Likewise, the court opined in United States v. Ross[5] that the Carroll doctrine permitted examination of all containers found in a vehicle during a search with probable cause.

[6] 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 within an automobile.

He found that precedent did not dictate the result, and he noted that Ross "categorically rejected the notion that the scope of a warrantless search of a vehicle might be 'defined by the nature of the container in which the contraband is secreted.

It is noteworthy that the early legislation on which the Court relied in Carroll concerned the enforcement of laws imposing duties on imported merchandise... .

Since Congress had authorized warrantless searches of vessels and beasts for imported merchandise, it is inconceivable that it intended a customs officer to obtain a warrant for every package discovered during the search; certainly Congress intended customs officers to open shipping containers when necessary and not merely to examine the exterior of cartons or boxes in which smuggled goods might be concealed.