State v. Kealey

Defendant Carolyn Ann Kealey misplaced her purse in a department store. Store personnel found unlawful drugs in the purse and contacted the police. Knowing the purse contained drugs, the police officers did not obtain a warrant, but searched the purse for identification. We hold that Kealey reasonably *165expected that her purse would remain private. We further hold that police may search misplaced property for identification without a search warrant. The police officers’ knowledge of the presence of unlawful drugs did not undermine the right to search for identification. We reverse the trial…