Knowles v. Iowa
Encyclopedia
Knowles v. Iowa, 525 U.S. 113
(1998), was a decision by the United States Supreme Court
which ruled that the Fourth Amendment
prohibits a police officer
from further searching a vehicle
which was stopped for a minor traffic offense once the officer has written a citation
for the offense.
, driving 43 MPH in a 25 zone. The police officer ticketed Knowles rather than arresting him, as was permitted under Iowa
law. The officer then searched the car
, finding marijuana and a "pot pipe." Knowles was then arrested and charged with violation of state laws dealing with controlled substances.
Before trial, Knowles argued the search was not applicable to the "search incident to arrest" exception recognized in United States v. Robinson
, 414 U. S. 218
(1973), because he had not been placed under arrest. At the hearing on the motion to suppress, the police officer conceded that he had neither Knowles' consent nor probable cause to conduct the search. He relied on Iowa law dealing with such searches.
Because Iowa Code
§321.485(1)(a) permits either an arrest or a citation when making a traffic stop, the Iowa Supreme Court
has interpreted this provision as providing authority to officers to conduct a full-blown search of an automobile
and driver in those cases where police elect not to make a custodial arrest. The trial court denied the motion to suppress and the defendant was convicted.
A divided Supreme Court of Iowa upheld the search and the conviction.
The U.S. Supreme Court decided that the search was unlawful.
Because, given the type of stop, there were no grounds for the officer to believe that his safety was in jeopardy, and thus had no probable cause to perform a search without consent of the driver. Also, since Knowles was not "in custody", there was no custodial exception to permit a search either. Thus the search was ruled illegal.
The Supreme Court reversed the case and remanded it for redetermination.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1998), was a decision by the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
which ruled that the Fourth Amendment
Fourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
prohibits a police officer
Police officer
A police officer is a warranted employee of a police force...
from further searching a vehicle
Vehicle
A vehicle is a device that is designed or used to transport people or cargo. Most often vehicles are manufactured, such as bicycles, cars, motorcycles, trains, ships, boats, and aircraft....
which was stopped for a minor traffic offense once the officer has written a citation
Citation
Broadly, a citation is a reference to a published or unpublished source . More precisely, a citation is an abbreviated alphanumeric expression Broadly, a citation is a reference to a published or unpublished source (not always the original source). More precisely, a citation is an abbreviated...
for the offense.
Case
Patrick Knowles was stopped in Newton, IowaNewton, Iowa
Newton is a city in and the county seat of Jasper County, Iowa, United States. As of the 2010 census, the city population was 15,254. It is the home of Maytag Dairy Farms and was formerly home to the Maytag Corporation's corporate headquarters until the Whirlpool Corporation acquired it in 2006...
, driving 43 MPH in a 25 zone. The police officer ticketed Knowles rather than arresting him, as was permitted under Iowa
Iowa
Iowa is a state located in the Midwestern United States, an area often referred to as the "American Heartland". It derives its name from the Ioway people, one of the many American Indian tribes that occupied the state at the time of European exploration. Iowa was a part of the French colony of New...
law. The officer then searched the car
Čar
Čar is a village in the municipality of Bujanovac, Serbia. According to the 2002 census, the town has a population of 296 people.-References:...
, finding marijuana and a "pot pipe." Knowles was then arrested and charged with violation of state laws dealing with controlled substances.
Before trial, Knowles argued the search was not applicable to the "search incident to arrest" exception recognized in United States v. Robinson
United States v. Robinson
United States v. Robinson, 414 U.S. 218 , was a case in which the United States Supreme Court held that "in the case of a lawful custodial arrest a full search of the person is not only an exception to the warrant requirement of the 4th Amendment, but is also a reasonable search under that...
, 414 U. S. 218
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1973), because he had not been placed under arrest. At the hearing on the motion to suppress, the police officer conceded that he had neither Knowles' consent nor probable cause to conduct the search. He relied on Iowa law dealing with such searches.
Because Iowa Code
Code of Iowa
The Code of Iowa contains the statutory laws of the State of Iowa. The Iowa Legislative Service Bureau is a non-partisan governmental agency that organizes, updates, and publishes the Iowa Code. It is republished in full every odd year, and is supplemented in even years.-External reference:....
§321.485(1)(a) permits either an arrest or a citation when making a traffic stop, the Iowa Supreme Court
Iowa Supreme Court
The Iowa Supreme Court is the highest court in the U.S. state of Iowa. As constitutional head of the Iowa Judicial Branch, the Court is composed of a Chief Justice and six Associate Justices....
has interpreted this provision as providing authority to officers to conduct a full-blown search of an automobile
Automobile
An automobile, autocar, motor car or car is a wheeled motor vehicle used for transporting passengers, which also carries its own engine or motor...
and driver in those cases where police elect not to make a custodial arrest. The trial court denied the motion to suppress and the defendant was convicted.
A divided Supreme Court of Iowa upheld the search and the conviction.
The U.S. Supreme Court decided that the search was unlawful.
Because, given the type of stop, there were no grounds for the officer to believe that his safety was in jeopardy, and thus had no probable cause to perform a search without consent of the driver. Also, since Knowles was not "in custody", there was no custodial exception to permit a search either. Thus the search was ruled illegal.
The Supreme Court reversed the case and remanded it for redetermination.
See also
- List of United States Supreme Court cases, volume 525
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume