State v. McKeever, 351 P.3d 676

Police stopped Kyle McKeever in December 2012 after recognizing him as a driver with a suspended license; he was nervous and then placed under arrest when suspension was confirmed.
During a lawful pat‑down incident to arrest, officers found a prescription pill bottle secreted in the cuff of McKeever’s pants.
The bottle bore another person’s name and listed Alprazolam (a controlled substance); officers asked McKeever about it and he responded that he did not know where it came from.
Officers opened the bottle and observed tissue over pills; McKeever was later charged with felony criminal possession of dangerous drugs and pled guilty while reserving the right to appeal the suppression ruling.
The district court denied the suppression motion, reasoning the bottle was discovered lawfully, McKeever had no reasonable privacy interest, and alternatively the inevitable‑discovery/inventory exceptions applied.
The Montana Supreme Court affirmed, holding there was no Fourth Amendment search because McKeever had relinquished any protectable privacy interest in the bottle.

Issue	Plaintiff's Argument (McKeever)	Defendant's Argument (State)	Held
Whether opening the prescription bottle after lawful seizure was an unconstitutional search	Opening the bottle while McKeever was handcuffed and under arrest violated privacy; no officer safety, escape risk, or exigency; inevitable‑discovery and inventory claims speculative	McKeever disclaimed any ownership/privacy interest; bottle bore another name and contained a controlled substance, so no reasonable expectation of privacy and no unconstitutional search	Affirmed: no constitutional “search” because McKeever voluntarily relinquished/abandoned any reasonable privacy interest in the bottle; (court did not rely on inevitable‑discovery though district court invoked it)

State v. Hilgendorf, 208 P.3d 401 (Mont. 2009) (inventory search and inevitable‑discovery discussion in context of items found on person)
State v. Demontiney, 324 P.3d 344 (Mont. 2014) (inventory searches not subject to probable‑cause requirement)
State v. Ellis, 210 P.3d 144 (Mont. 2009) (explaining inevitable‑discovery exception)
State v. Hill, 94 P.3d 752 (Mont. 2004) (abandonment/voluntary relinquishment removes reasonable expectation of privacy)
State v. Lanegan, 91 P.3d 578 (Mont. 2004) (search incident to arrest principles)
State v. Goetz, 191 P.3d 489 (Mont. 2008) (reasonable expectation of privacy test under Montana Constitution)
State v. 1993 Chevrolet Pickup, 116 P.3d 800 (Mont. 2005) (abandonment of property as ground to deny expectation of privacy)
State v. Hamilton, 67 P.3d 871 (Mont. 2003) (recognizing privacy in closed containers)
United States v. Ross, 456 U.S. 798 (U.S. 1982) (containers and Fourth Amendment protection)
Simmons v. United States, 390 U.S. 377 (U.S. 1968) (right to remain silent and protection against self‑incrimination)