B. The Effect of an Unlawful Secondary Purpose

[9] This Court held that an unlawful secondary purpose
invalidates an otherwise permissible administrative search
scheme in $124,570. See $124,570, 873 F.2d at 1247.
$124,570 addressed the validity of administrative searches for
weapons in the carry-on bags of airline passengers. See id. at
1240. The $124,570 court acknowledged that an administra-
tive search for weapons and explosives is valid. See id. at
1246. The court, however, found that where the scope of the
search was no longer for purely administrative purposes, but
included criminal investigatory purposes, it could no longer
be justified as an administrative search. See id . at 1246 n.5.

In $124,570, the Flight Terminal Security officers ("FTS
officers") executing the searches had a dual purpose when
conducting the search. In $124,570, the United States Cus-
toms Service and Port Police had a policy of giving FTS offi-
cers a $250 reward for reporting a passenger carrying over
$10,000 in currency. See id. at 1241.

With this policy in place, a dark mass was revealed when
the defendant's briefcase passed through an airline's x-ray
scanner. See id. The FTS officer asked the defendant to open
the briefcase, revealing a large sum of money. See id. The
FTS officer returned the briefcase to the defendant and
allowed him to proceed on his scheduled flight from Seattle
to Los Angeles. See id. The FTS officer notified the appropri-
ate authorities and the defendant was subsequently arrested in
conjunction with this currency. See id. at 1241-42.

Holding that this search was invalid, the $124,570 court
noted that the FTS officers had very broad latitude in deter-
mining whether or not to search a package. See id. at 1245.
The court reasoned that if the sole purpose of the search was
to find weapons or explosives, the court could defer to the
guard's judgment regarding when to search a bag. See id. The
addition of the dual motive created a different set of facts
because "the decision to open a particular briefcase may be
motivated by the desire to comply with the FTS's cooperation
policy." See id. Therefore, the FTS officers might choose to
search bags more often or to do more extensive searches
because of the dual motive. See id. at 1246. Because the dual
motive extended the scope of the administrative search
beyond the reasonableness standard of the Fourth Amend-
ment, the court held that the search was invalid. See id. at
1247.