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Hmm, good question. If it's not locked properly, then I think it will. And that suitcase's lock is already failing right? That's why the Niffler escaped in part 1. Newt should change the lock and probably put a spell that no animals escape it in case the lock is faulty.
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I guess the Niffler has some magic to break into or out of something of it's own and is difficult to trap?