Citation. Knowles v. Iowa, 525 U.S. 113, 119 S. Ct. 484, 142 L. Ed. 2d 492, 1998 U.S. LEXIS 8068, 67 U.S.L.W. 4027, 98 Daily Journal DAR 12417, 1998 Colo. J. C.A.R. 6164 (U.S. Dec. 8, 1998)
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.
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.”ť