State v. Wisdom, 349 P.3d 953

Wisdom, driver of a stolen pickup, was arrested after the vehicle was identified as stolen.
A black shaving-kit bag on the front seat contained methamphetamine, plus other drugs and cash.
Deputy Boyer opened the bag without a warrant or Wisdom’s consent, revealing additional contraband.
Wisdom was charged with possession of cocaine, ecstasy, heroin, and methamphetamine with intent to deliver.
The trial court denied suppression; Wisdom challenged the search as unlawful under Washington law.
The court of appeals reverses, holding the search unlawful under Washington’s article I, section 7.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge the search	Wisdom had possessory interest; automatic standing applies.	Wisdom lacked privacy/standing because bag found in stolen vehicle.	Wisdom has standing under Washington law; the analysis proceeds.
Search incident to arrest	Search of bag justified to seize evidence of arrest crime.	Gant/Snapp restrict such searches post-arrest; no warrantless search allowed.	Not justified by search incident to arrest under state constitution.
Inventory search exception	Bag opened as part of inventory to protect against loss.	Inventory search permitted; opened bag within scope to count money.	Inventory search did not justify opening the bag; scope and purposes misapplied.

State v. Snapp, 174 Wn.2d 177 (2012) (article I, § 7 protections require warrant; not like Fourth Amendment)
State v. Valdez, 167 Wn.2d 761 (2009) (state constitution requires authority of law for disturbances)
State v. Houser, 95 Wn.2d 143 (1980) (privacy in toiletry kit; closed container searches limited)
State v. White, 135 Wn.2d 761 (1998) (inventory searches; protect against theft; limits on contents)
State v. Zakel, 119 Wn.2d 563 (1992) (standing determined; ownership at time of search)
State v. Doughty, 170 Wn.2d 57 (2010) (narrow exceptions to warrant requirement; burden on State)