Heather Ryon v. State of Indiana (mem. dec.), 49A02-1609-CR-2079

On March 15, 2016, Beech Grove police stopped a vehicle; Heather Ryon (rear passenger) was identified and found to have an active warrant, then handcuffed.
An elderly front-seat passenger (vehicle owner) consented to a brief search of the vehicle; Officer Parker retrieved a purse from the rear seat that he observed near Ryon.
Officer Parker asked Ryon whether the purse was hers and whether she wanted it taken to jail with her; Ryon said it was hers and answered yes when asked if she wanted it to go to jail.
Officer Parker placed the purse on his patrol car in bright light, searched it, and found a small velvet cinch bag containing a glass pipe; testing showed methamphetamine residue.
Ryon moved to suppress statements and items found in the search; the trial court denied suppression, convicted Ryon of possession of paraphernalia (Class C misdemeanor), and she appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless search of the purse was lawful under the Fourth Amendment	Search was incident to a lawful arrest (Robinson); alternatively, Gant allows vehicle searches when unsecured persons remain who could access items; inevitable discovery (processing at jail)	Search was not consensual or incident to arrest because Ryon was secured and away from vehicle; owner’s consent to car search didn’t authorize search of Ryon’s purse; no inventory policy followed	Court held the purse was immediately associated with Ryon and the search was reasonable as incident to arrest; inevitable discovery would also make the pipe admissible under federal Fourth Amendment principles
Whether the search violated Article 1, § 11 of the Indiana Constitution	Search reasonable under totality of circumstances (degree of suspicion, intrusion, and law enforcement needs); Ryon had an arrest warrant and indicated ownership and request to transport purse to jail	Ryon relied on Pirtle and related precedent requiring explicit waiver when in custody; argued heightened state-constitutional protection and distinguishable prior purse-search cases	Court applied Litchfield factors, found low intrusion, legitimate law-enforcement need (officer safety/inspection of seized item), and concluded search was reasonable under Article 1, § 11

Riley v. California, 134 S. Ct. 2473 (U.S. 2014) (discusses limits of search-incident-to-arrest doctrine and privacy interests in modern cell phones)
United States v. Robinson, 414 U.S. 218 (U.S. 1973) (custodial arrest justifies search of person and personal effects without additional justification)
Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (limits vehicle searches incident to arrest to situations where arrestee could access compartment or where evidence of the crime of arrest might be found)
Garcia v. State, 47 N.E.3d 1196 (Ind. 2016) (Indiana Supreme Court endorsing Robinson’s standard for search incident to arrest)
Nix v. Williams, 467 U.S. 431 (U.S. 1984) (articulates the inevitable discovery exception to the exclusionary rule)
Pirtle v. State, 323 N.E.2d 634 (Ind. 1975) (addresses custodial waiver/consent issues under Indiana constitutional protections)