State v. Caulfield, 995 N.E.2d 941

At 1:40 a.m., deputies stopped a car for an obscured license plate; Michelle Caulfield was the front-seat passenger. The driver had an outstanding warrant and was arrested. No warrant information for Caulfield was returned.
The driver consented to a vehicle search and was placed in a patrol cruiser; deputies then ordered Caulfield to exit and to leave her purse in the vehicle.
Deputy Wright searched Caulfield’s purse (Wright claimed he had consent; the trial court credited Caulfield that she did not consent) and found drugs, syringes, scales, and baggies; deputies later located drugs in her bra after further search and pat-down by a female officer.
Caulfield moved to suppress all evidence obtained from the purse and undergarments as the product of an unlawful search and seizure; the trial court granted the motion.
The State appealed, arguing the search was reasonable for officer safety and/or based on Caulfield’s consent; the court of appeals affirmed suppression.

Issue	State's Argument	Caulfield's Argument	Held
Legality of continued detention of passenger after driver’s arrest	Detention was reasonable as a necessary corollary to the traffic stop and contemporaneous with a lawful vehicle search	Continued detention was unsupported by reasonable suspicion and thus unlawful	Detention was lawful — passenger may be detained while officers control scene and search vehicle
Validity of consent to search purse	Wright reasonably ordered purse left in car and Caulfield consented to search	Caulfield did not consent; driver’s consent to search vehicle did not extend to her purse	Trial court’s credibility finding that Caulfield did not consent is controlling; driver lacked common authority over purse, so no valid third-party consent
Validity of searching purse under "search-incident-to-arrest" or officer-safety exception	Search incident to the driver’s arrest and officer-safety justified searching containers in the passenger compartment	Gant limits Belton: no occupant was within reaching distance and no reason to believe vehicle contained evidence of the offense; no officer-safety basis shown	Search-incident-to-arrest and officer-safety exceptions did not apply; ordering the purse left in the vehicle without probable cause and then searching it violated the Fourth Amendment — suppression affirmed

Maryland v. Wilson, 519 U.S. 408 (police may order passengers out of a stopped vehicle)
Arizona v. Johnson, 555 U.S. 323 (temporary seizure of passengers continues while police control the scene)
Chimel v. California, 395 U.S. 752 (scope of search incident to arrest limited to arrestee and area within immediate control)
New York v. Belton, 453 U.S. 454 (search of passenger compartment incident to arrest — later narrowed)
Arizona v. Gant, 556 U.S. 332 (vehicle search incident to arrest permitted only if arrestee within reaching distance or vehicle likely contains evidence of the offense)
United States v. Matlock, 415 U.S. 164 (third-party consent requires common authority)
Schneckloth v. Bustamonte, 412 U.S. 218 (consent to search must be voluntary)
Katz v. United States, 389 U.S. 347 (warrant requirement under Fourth Amendment)