Technically, in many states, an empty can/bottle of alcohol in the passenger compartment is enough to arrest the driver for DUI even if they blow a 0.0. In essence what it is is an open container. So having the recyling bin in the back of the minivan with the cans in paper bags is enough. However, I think the cop and the prossecutor would have to be a real jerk to actually prosecute/arrest the person for that. Even though they could.