Patrick Knowles was pulled over for speeding in Iowa. The officer ticketed Knowles instead of arresting him and then searched his car without a warrant or consent, finding marijuana and paraphernalia. Iowa law allows officers to use discretion in determining whether to arrest or issue a citation to traffic incidents, which has implied that officers can search a vehicle as if they were arresting the individual behind the wheel. Knowles argued that the officer’s search was unconstitutional as it cannot apply to the rule created in United States v. Robinson (1973), which affirmed that officers can search a person incident to their arrest, as he was not arrested. The Supreme Court of Iowa upheld the conviction. The Supreme Court unanimously ruled that full searches of the vehicle can only be done if the officers feel as though they are at risk. In this case, the traffic stop was routine and Knowles provided no reason to alarm the officer, nor did the officer have probable cause to search the vehicle without Knowles’s consent. The court reversed the decision, ruling that the search was unreasonable because it was not consistent with a search incident to arrest, and remanded the case to be redetermined at the lower level.
Knowles v. Iowa
525 US 113 (1998)
(The Search witha Citation Case)
Knowles was stopped in Newton, Iowa, after having been clocked driving 43 miles per hour on a road where the speed limit was 25 miles per hour. The police officer issued a citation to Knowles, although under Iowa law he might have arrested him. The officer then conducted a full search of the car, and under the driver's seat he found a bag of marijuana and a "pot pipe." Knowles was then arrested and charged with violation of state laws dealing with controlled substances.
Whether stopping someone for speeding but issuing a citation rather than arresting them authorizes the officer, consistently with the Fourth Amendment, to conduct a full search of the car.
There are 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. But neither of these underlying rationales for the search incident to arrest exception is sufficient to justify the search in the present case.
The threat to officer safety from issuing a traffic citation is a good deal less than in the case of a custodial arrest. We recognized that "the danger to the police officer flows from the fact of the arrest, and its attendant proximity, stress, and uncertainty, and not from the grounds for arrest."A routine traffic stop, on the other hand, is a relatively brief encounter and "is more analogous to a so-called 'Terrystop' . . . thanto a formal arrest.
While the concern for officer safety in this context may justify the "minimal" additionalintrusion of ordering a driver and passengers out of the car, it does not by itself justify the often considerably greater intrusion attending a full field-type search. Even without the search authority Iowa urges, officers have other, independent bases to search for weapons and protect themselves from danger. For example, they may order out of a vehicle both the driver, and any passengers; perform a "pat-down" of a driver and any passengers upon reasonable suspicion that they may be armed and dangerous; conduct a Terrypat-down" of the passenger compartment of a vehicle upon reasonable suspicion that an occupant is dangerous and may gain immediate control of a weapon; and even conduct a full search of the passenger compartment, including any containers therein, pursuant to a custodial arrest.
Nor has Iowa shown the second justification for the authority to search incident to arrest -- the need to discover and preserve evidence. 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.
As for the destruction of evidence relating to identity, if a police officer is not satisfied with the identification furnished by the driver, this may be a basis for arresting him rather than merely issuing a citation. As for destroying evidence of other crimes, the possibility that an officer would stumble onto evidence wholly unrelated to the speeding offense seems remote.
The search at issue, authorized as it was by state law, nonetheless violates the Fourth Amendment.
The SILA exception only applies to actual arrests and not merely arrestableoffenses.
An Iowa policeman stopped petitioner Knowles for speeding and issued him a citation rather than arresting him. The officer then conducted a full search of the car, without either Knowles' consent or probable cause, found marijuana and a "pot pipe," and arrested Knowles. Before his trial on state drug charges, Knowles moved to suppress the evidence, arguing that because he had not been arrested, the search could not be sustained under the "search incident to arrest" exception recognized in United States v. Robinson. The trial court denied the motion and found Knowles guilty, based on state law giving officers authority to conduct a full-blown search of an automobile and driver where they issue a citation instead of making a custodial arrest. In affirming, the State Supreme Court applied its bright-line "search incident to citation" exception to the Fourth Amendment's warrant requirement, reasoning that so long as the officer had probable cause to make a custodial arrest, there need not in fact have been an arrest.
Held: The search at issue, authorized as it was by state law, nonetheless violates the Fourth Amendment. Neither of the two historical exceptions for the "search incident to arrest" exception is sufficient to justify the search in the present case. First, the threat to officer safety from issuing a traffic citation is a good deal less than in the case of a custodial arrest. While concern for safety during a routine traffic stop may justify the "minimal" additional intrusion of ordering a driver and passengers out of the car, it does not by itself justify the often considerably greater intrusion attending a full field-type search. Even without the search authority Iowa urges, officers have other, independent bases to search for weapons and protect themselves from danger. Second, the need to discover and preserve evidence does not exist in a traffic stop, for once Knowles was stopped for speeding and issued a citation, all evidence necessary to prosecute that offense had been obtained. Iowa's argument that a "search incident to citation" is justified because a suspect may try to hide evidence of his identity or of other crimes is unpersuasive. An officer may arrest a driver if he is not satisfied with the identification furnished, and the possibility that an officer would stumble onto evidence of an unrelated offense seems remote.
How the Justices Voted
Majority: Rehnquist, joined by unanimous