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Supreme Court· 12/8/1998

Knowles v. Iowa

Citations

  • 525 U.S. 113
  • 119 S. Ct. 484
  • 142 L. Ed. 2d 492
  • 1998 U.S. LEXIS 8068

About this case

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From Wikipedia, the free encyclopedia

1998 United States Supreme Court case

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.[1]

Background

[(https://en.wikipedia.org/w/index.php?title=Knowles_v._Iowa&action=edit&section=1 "Edit section: Background")
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Patrick Knowles was stopped in Newton, Iowa , driving 43 mph (69 km/h ) in a 25 mph (40 km/h) 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 _,[2] 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 Iowa Supreme Court upheld the search and the conviction.[3]

Supreme Court

[(https://en.wikipedia.org/w/index.php?title=Knowles_v._Iowa&action=edit&section=2 "Edit section: Supreme Court")
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The U.S. Supreme Court decided that the search was unlawful.

Once Knowles was stopped for speeding and issued a citation, all the evidence necessary to 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 passenger compartment of the car.

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.

Further reading

[(https://en.wikipedia.org/w/index.php?title=Knowles_v._Iowa&action=edit&section=3 "Edit section: Further reading")
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  • Gillespie, Daniel T. (1999). "Bright-Line Rules: Development of the Law of Search and Seizure during Traffic Stops". Loyola University Chicago Law Journal. 31: 1.

References

[(https://en.wikipedia.org/w/index.php?title=Knowles_v._Iowa&action=edit&section=4 "Edit section: References")
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  1. ↑ Knowles v. Iowa, 525 U.S. 113 (1998)  This article incorporates public domain material from this U.S government document .
  2. ↑ _United States v. Robinson _, 414 U.S. 218 (1973).
  3. ↑ State v. Knowles, 569 N.W.2d 601 (Iowa 1997).

External links

[(https://en.wikipedia.org/w/index.php?title=Knowles_v._Iowa&action=edit&section=5 "Edit section: External links")
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United States Fourth Amendment case law

Scope of the Fourth Amendment

Definition of search

Definition of seizure

Third-party entry

Fourth Amendment standing

Warrant requirement

…

Editorial context from Wikipedia (CC-BY-SA 4.0).

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • holding that a search, without consent or probable cause, of a car belonging to person given a citation for speeding, violates the Fourth Amendment
  • holding that if one is pulled over for a legitimate traffic stop and the officer has no reasonable reason to search, then a full search of the vehicle is unreasonable
  • concluding that the detention of a person to be issued a citation does not amount to a full custodial arrest, but is “more analogous to a so-called ‘Terry stop’”
  • holding that the existence of probable cause to arrest the suspect did not render the officer's warrantless search of his car lawful when the officer did not intend to effect an arrest
  • finding that the danger to the officers “flows from the fact of the arrest, and its attendant proximity, stress, and uncertainty”
  • stating that a general concern for officer safety during a traffic stop does not by itself justify the intrusion of a “full field-type search.”

Source: CourtListener parenthetical corpus (CC0).

Judges: Rehnquist

Read full opinion on CourtListener

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.