State v. Ashli Marie Easterday, 159 Idaho 173

Easterday was stopped for driving a vehicle loaned to her by the owner’s ex-girlfriend; a drug dog alerted on the vehicle after a car stop; Easterday’s purse sat on the bench seat beside her during the stop; she exited with the purse; deputy searched the purse after indicating it was in the car when the dog alerted; methamphetamine and paraphernalia were found; she pled guilty to possession and appealed the suppression denial.
The district court held the purse was not part of Easterday’s person, so its contents were within the automobile exception’s scope; the drug-dog alert established probable cause to search the vehicle; the appeal concerns whether the purse could be searched under the automobile exception.
Easterday argued the purse was part of her person and not subject to search under the automobile exception; the State argued purses are containers within a vehicle that may be searched when probable cause exists; the issue is whether a purse can be treated as part of a person for Fourth Amendment purposes under the automobile exception.
The court affirmed the suppression denial, holding that purses are containers within a vehicle and not part of a person for purposes of the automobile exception, and that the dog’s alert provided probable cause to search the vehicle and its contents, including the purse.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Easterday’s purse part of her person for Fourth Amendment purposes?	Easterday: purse is part of her person.	State: purse is a container within the vehicle.	Not part of person; automobile exception applies to purse.
Does a dog alert provide probable cause to search the vehicle and its contents, including the purse?	Easterday: only vehicle search authorized.	State: dog alert creates probable cause for vehicle and its contents.	Yes; probable cause justified search of vehicle and purse.
Does the automobile exception permit search of all containers inside the vehicle when probable cause exists?	N/A	N/A	Yes; containers within the vehicle may be searched; only the person is protected.

United States v. Ross, 456 U.S. 798 (U.S. 1982) (probable cause to search vehicle permits searching containers within it)
State v. Smith, 152 Idaho 115 (Ct. App. 2011) (container search within vehicle under automobile exception)
Wyoming v. Houghton, 526 U.S. 295 (U.S. 1999) (permits search of container belonging to occupant of vehicle)
Gibson v. Idaho, 141 Idaho 277 (Ct. App. 2005) (search of wallet inside jacket exceeded automobile exception scope)
State v. Roe, 140 Idaho 176 (Ct. App. 2004) (purses/wallets as personal containers; impact on search scope)