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Law School Case Brief

Knowles v. Iowa - 525 U.S. 113 (1998)


Two historical rationales for the search incident to arrest exception include: (1) the need to disarm the suspect in order to take him into custody, and (2) the need to preserve evidence for later use at trial.


Defendant Patrick Knowles was stopped by a police officer for speeding and was issued a citation. The officer then conducted a full search of Knowles' car, incident to the citation—in addition to authorizing police officers to issue a citation to a person who violated a traffic or motor vehicle equipment law, Iowa statutes authorized police officers to arrest such a person. The officer found a bag of marijuana and a "pot pipe." Knowles was then arrested and charged with violation of Iowa state laws dealing with controlled substances. Before being tried in a state court on the marijuana charges, Knowles filed a motion to suppress the marijuana and pipe, arguing that the search violated the Federal Constitution's Fourth Amendment because the search was not incident to an arrest. The trial court denied the motion, ruling that an Iowa statutory provision that the issuance of a citation in lieu of arrest did not affect the officer's authority to conduct an otherwise lawful search had been interpreted by the Supreme Court of Iowa in prior cases as authorizing a full search of an automobile and driver incident to citation. Knowles was found guilty. On appeal, the Supreme Court of Iowa affirmed the conviction. Knowles was granted a writ of certiorari.


Did the search of Knowles' car violate the Fourth Amendment?




The Supreme Court of the  United States reversed and remanded the case for further proceedings. The Court held that the issuance of the citation did not authorize the officer, consistently with the Fourth Amendment, to conduct a full search of the car. The Court observed that neither of the two historical exceptions for the "search incident to arrest" exception was sufficient to justify the search. First, the threat to officer safety from issuing a traffic citation was a good deal less than in the case of a custodial arrest. Concern for safety during a routine traffic stop did not by itself justify the intrusion attending a full field-type search. Second, the need to discover and preserve evidence did not exist, as once Knowles was stopped for speeding and issued a citation, all evidence necessary to prosecute that offense had been obtained.

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