State v. Maloney, 168 Idaho 936

Twin Falls officer stopped Maloney for expired registration; Maloney consented to a vehicle search while her purse was on the car floor.
As Maloney and a passenger exited, Maloney took her purse with her; she did not consent to a separate purse search.
Officers found a one-hitter pipe with marijuana residue inside the car (in a bag belonging to Maloney’s ex‑husband).
After finding the pipe, the officer claimed probable cause and searched Maloney’s purse (now outside the car), discovering pipes and a substance later presumptively identified as methamphetamine.
Maloney moved to suppress; the district court denied the motion (holding the automobile exception covered containers that had been in the car at the time of the stop), and Maloney entered a conditional guilty plea reserving appeal.
The Idaho Supreme Court reversed: the automobile exception did not permit searching a container removed from the vehicle before probable cause developed; judgment vacated and case remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the automobile exception permit searching a container removed from a vehicle before probable cause arises?	State: container need only have been in vehicle at time of the stop (or generally associated with vehicle) — exception should apply.	Maloney: automobile exception applies only to containers that are inside the vehicle when probable cause develops.	Court: automobile exception does not apply; container must be in vehicle when probable cause arises.
Did Maloney’s consent to search the car extend to purse after she removed it (or was consent revoked)?	State/dissent: consent (or the subsequent probable cause) justified searching the purse because it had been in the car when consent was given.	Maloney: removing the purse limited/revoked consent; she did not consent to a separate purse search.	Majority: State relied solely on automobile exception; consent did not justify the purse search and removal limited scope of consent; search suppressed.

United States v. Ross, 456 U.S. 798 (automobile exception permits searching containers within vehicle)
Wyoming v. Houghton, 526 U.S. 295 (officers with probable cause may inspect passengers’ belongings found in the car)
California v. Acevedo, 500 U.S. 565 (scope of container searches under automobile exception)
United States v. Johns, 469 U.S. 478 (probable cause to search vehicle permits search of containers found inside)
Schneckloth v. Bustamonte, 412 U.S. 218 (legal standard for voluntary consent to search)
State v. Anderson, 154 Idaho 703 (Idaho recognition and application of automobile exception)
State v. Gallegos, 120 Idaho 894 (location of container within automobile controls applicability of automobile exception)
State v. Greub, 162 Idaho 581 (consent can be limited or revoked; removing a container may limit scope of prior consent)
State v. Easterday, 159 Idaho 173 (Ct. App.) (purse treated as a vehicle container when it remained in car at time of drug-dog alert)
State v. Smith, 152 Idaho 115 (Ct. App.) (discusses Ross and application to items removed from vehicle)