Knowles v. Iowa

Brief Fact Summary. A police officer pulled over a speeder, issued a citation rather than arrest, and then searched the speeder’s car, finding drugs. The search was authorized by Iowa law even though there was no arrest.

Synopsis of Rule of Law. An officer issuing a traffic citation cannot search the cited person’s vehicle.

Facts. Petitioner Knowles was stopped for driving 43 mph in a 25 mph zone. The officer issued a citation, and then searched the petitioner’s car, discovering a bag of marijuana and a pipe. Under Iowa code, an officer may arrest a traffic violator, or he may issue a citation. The law permitted a search of the vehicle in either case.

Issue. “[W]hether [issuing a citation or similar] such . . . procedure authorizes the officer, consistently with the Fourth Amendment, to conduct a full search of the car.”

Held. No. The court cited two historical rationales for the search incident to arrest exception: (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.” The court concluded that “neither of these rationales . . . [are] sufficient.” For the former, the court reasoned that “a routine traffic stop . . . is a relatively brief encounter.” For the latter, the court argued that once the respondent was issued a citation “all the evidence necessary to prosecute that offense has been obtained. No further evidence was going to be found either on the person of the offender or in the passenger compartment of the car.”

Discussion. The court was unwilling to extend a rule of “search incident to citation” in a situation “where the concern for officer safety is not present to the same extent and the concern for the destruction or loss of evidence is not present at all.”