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Knowles v. Iowa, 525 U.S.

113 (1998)

"as applied," in which case, his challenge would run afoul of Sibron v. New York

HOLDING: A law enforcement officer may not search a person's vehicle without
their consent when they are not in custody once they have been cited.
Knowles' Argument: Because the officer had no probable cause and no search
warrant, and the search cannot otherwise be justified under the 4th
Chief Justice Rehnquist
Amendment, the search of the car was unconstitutional."
Patrick Knowles was stopped in Newton, Iowa, after having been clocked driving SC clarification: Knowles did not argue does not argue that the statute could
43 mph(road speed limit was 25 mph). The police officer issued a citation to
never be lawfully applied. The issue is
Knowles, although under Iowa law he might have arrested him. The officer then
conducted a full search of the car, and under the driver's seat he found a bag of WON the search done, authorized as it was by state law, nonetheless violates the
marijuana and a "pot pipe." Knowles was then arrested and charged with
Fourth Amendment.
violation of state laws dealing with controlled substances.
Held: No
In Robinson, SC noted the 2 historical rationales for the "search incident to
Before trial, Knowles moved to suppress the evidence: search could not be
arrest" exception: (1) the need to disarm the suspect in order to take him into
sustained under the "search incident to arrest" exception recognized in US v. custody, and (2) the need to preserve evidence for later use at trial.
Robinson (1973), because he had not been placed under arrest.
Note: the police officer conceded that he had neither Knowles' consent nor
(1) The first rationale--officer safety--is " both legitimate and weighty. The
probable cause to conduct the search. He relied on Iowa law dealing with such threat to officer safety from issuing a traffic citation, however, is a good deal less
than in the case of a custodial arrest.
S805.1(4) provides that the issuance of a citation in lieu of an arrest "does not
A routine traffic stop, on the other hand, is a relatively brief encounter and "is
affect the officer's authority to conduct an otherwise lawful search."
more analogous to a so-called ` Terry stop' ... than to a formal arrest." Berkemer
The Iowa SC has interpreted this provision as providing authority to officers to v. McCarty (1984).
conduct a full-blown search of an automobile and driver in those cases where
police elect not to make a custodial arrest and instead issue a citation--that is, a But while the concern for officer safety in this context may justify the "minimal"
search incident to citation.
additional intrusion of ordering a driver and passengers out of the car, it does
not by itself justify the often considerably greater intrusion attending a full
Based on this, the TC denied the motion to suppress and found Knowles guilty. field-type search.
The SC of Iowa, sitting en banc, upheld (by a divided vote) the constitutionality (2) Nor has Iowa shown the second justification for the authority to search
of the "search incident to citation", reasoning that so long as the arresting
incident to arrest--the need to discover and preserve evidence. Once Knowles
officer had probable cause to make a custodial arrest, there need not in fact have was stopped for speeding and issued a citation, all the evidence necessary to
been a custodial arrest.
prosecute that offense had been obtained. No further evidence of excessive
speed was going to be found either on the person of the offender or in the
Hence this writ of certiorari.
passenger compartment of the car.
DECISION: The judgment of the SC of Iowa is reversed, and the cause remanded
State's contention: Knowles has challenged Iowa Code only "on its face" and not for further proceedings not inconsistent with this opinion.