Knowles v. Iowa
525 U.S. 113 (1998)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The Fourth Amendment's 'search incident to arrest' exception does not permit a police officer to conduct a full search of a vehicle when the officer only issues a traffic citation and does not make a lawful custodial arrest.
Facts:
- An Iowa police officer stopped Patrick Knowles for driving 43 miles per hour in a 25-mile-per-hour zone.
- Under Iowa law, the officer had the authority to place Knowles under custodial arrest for the speeding violation.
- The officer elected not to arrest Knowles and instead issued him a citation for speeding.
- After issuing the citation, the officer conducted a full search of Knowles's car.
- The search revealed a bag of marijuana and a 'pot pipe' under the driver's seat.
- Upon discovering the contraband, the officer arrested Knowles.
Procedural Posture:
- Knowles was charged in Iowa state trial court with violations of state controlled substance laws.
- Knowles filed a pretrial motion to suppress the evidence, arguing the search of his car violated the Fourth Amendment.
- The trial court denied the motion, finding the search was authorized as a 'search incident to citation' under Iowa law.
- Following a trial, Knowles was found guilty.
- Knowles appealed his conviction to the Supreme Court of Iowa.
- The Supreme Court of Iowa affirmed the trial court's decision, upholding the constitutionality of the search.
- The United States Supreme Court granted Knowles's petition for a writ of certiorari.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the Fourth Amendment permit a police officer to conduct a full warrantless search of a car as 'incident to citation' when the officer has probable cause to make a custodial arrest for a traffic violation but chooses to issue a citation instead?
Opinions:
Majority - Chief Justice Rehnquist
No. A full search of an automobile conducted after an officer issues a traffic citation, rather than making a custodial arrest, violates the Fourth Amendment. The traditional rationales justifying the search incident to arrest exception—officer safety and the need to preserve evidence—do not apply in the context of a 'search incident to citation.' First, the threat to officer safety is significantly less during a routine traffic stop where a citation is issued compared to the extended exposure of a custodial arrest. While officer safety is a concern, it justifies lesser intrusions like ordering the driver out of the car or a Terry patdown if suspicion arises, not a full search. Second, the need to preserve evidence is not present for a traffic violation like speeding, as all necessary evidence has already been obtained once the officer stops the vehicle and issues the citation. Therefore, the Court declined to extend the bright-line rule of United States v. Robinson to situations where no custodial arrest occurs.
Analysis:
This unanimous decision clarifies and limits the scope of the 'search incident to arrest' exception to the Fourth Amendment's warrant requirement. The Court refused to detach the authority to conduct a warrantless search from the fact of a custodial arrest, thereby preventing states from creating a new 'search incident to citation' exception by statute. This ruling reinforces the principle that the justification for a warrantless search must be closely tied to the circumstances that make it necessary, such as the inherent dangers and evidentiary risks of taking a suspect into custody. It significantly protects the privacy interests of motorists during routine traffic stops that do not result in an arrest.
