In Wyoming v. Houghton the United States Supreme Court addressed the constitutionality of conducting a warrantless search of a container under the "automobile exception" to the Fourth Amendment's warrant requirement. The Court held that when police officers have probable cause to search a vehicle, they may also search any container found in the car, including passengers' belongings, that are capable of concealing the object of the search.
Hammond, Theresa H.
"Wyoming v. Houghton: Passengers' Belongings Subject to Searches Under the "Automobile Exception" to the Fourth Amendment's Warrant Requirements,"
Mercer Law Review: Vol. 51:
3, Article 12.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol51/iss3/12