''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 A citation is a reference to a source. More precisely, a citation is an abbreviated alphanumeric expression embedded in the body of an intellectual work that denotes an entry in the bibliographic references section of the work for the purpose of ...

for the offense.

Background

Patrick Knowles was stopped in Newton, Iowa, driving in a zone. The police officer ticketed Knowles rather than arresting him, as was permitted under Iowa law. The officer then searched the

car A car or automobile is a motor vehicle with wheels. Most definitions of ''cars'' say that they run primarily on roads, seat one to eight people, have four wheels, and mainly transport people instead of goods. The year 1886 is regarded as ...

, finding

marijuana Cannabis, also known as marijuana among other names, is a psychoactive drug from the cannabis plant. Native to Central or South Asia, the cannabis plant has been used as a drug for both recreational and entheogenic purposes and in various tra ...

and a "pot pipe." Knowles was then arrested and charged with violation of state laws dealing with

controlled substances A controlled substance is generally a drug or chemical whose manufacture, possession and use is regulated by a government, such as illicitly used drugs or prescription medications that are designated by law. Some treaties, notably the Single C ...

. 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'', 414 U.S. 218 (1973), 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 Fo ...

'', 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.

Supreme Court

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.

References

External links

* {{US4thAmendment, warrantexceptions, state=expanded United States Fourth Amendment case law United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court Legal history of Iowa 1998 in United States case law Jasper County, Iowa

Background

Supreme Court

See also

Further reading

References

External links