Knowles v. Iowa, 977597

CourtUnited States Supreme Court
Writing for the CourtRehnquist
Citation119 S.Ct. 484,525 U.S. 113
Decision Date08 December 1998
Docket Number977597

525 U.S. 113

119 S. Ct. 484


No. 97-7597


November 3, 1998, Argued

December 8, 1998, Decided

COUNSEL: Paul Rosenberg argued the cause for petitioner.

Bridget A. Chambers argued the cause for respondent.

JUDGES: REHNQUIST, C. J., delivered the opinion for a unanimous Court.



[525 U.S. 114] [119 S. Ct. 486] CHIEF JUSTICE REHNQUIST delivered the opinion of the Court.

An Iowa police officer stopped petitioner Knowles for speeding, but issued him a citation rather than arresting him. The question presented is whether such a procedure authorizes the officer, consistently with the Fourth Amendment, to conduct a full search of the car. We answer this question "no."

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.

Before trial, Knowles moved to suppress the evidence so obtained. He argued that the search could not be sustained under the "search incident to arrest" exception recognized in United States v. Robinson, 414 U.S. 218, 38 L. Ed. 2d 427, 94 S. Ct. 467 (1973), because he had not been placed under arrest. At the hearing on the motion to suppress, the police officer conceded that he had [525 U.S. 115] neither Knowles' consent nor probable cause to conduct the search. He relied on Iowa law dealing with such searches.

Iowa Code Ann. § 321.485(1)(a) (West 1997) provides that Iowa peace officers having cause to believe that a person has violated any traffic or motor vehicle equipment law may arrest the person and immediately take the person before a magistrate. Iowa law also authorizes the far more usual practice of issuing a citation in lieu of arrest or in lieu of continued custody after an initial arrest. 1 [119 S. Ct. 487] See Iowa Code Ann. § 805.1(1) (West Supp. 1997). Section 805.1(4) provides that the issuance of a citation in lieu of an arrest "does not affect the officer's authority to conduct an otherwise lawful search." 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 and instead issue a citation -- that is, a search incident to citation. See State v. Meyer, 543 N.W.2d 876, 879 (1996); State v. Becker, 458 N.W.2d 604, 607 (1990).

Based on this authority, the trial court denied the motion to suppress and found Knowles guilty. The Supreme Court of Iowa, sitting en banc, affirmed by a divided vote. 569 N.W.2d 601 (1997). Relying on its earlier opinion in State v. Doran, 563 N.W.2d 620 (1997), the Iowa Supreme Court upheld the constitutionality of the search under a bright-line "search incident to citation" exception to the Fourth Amendment's warrant requirement, reasoning that so long as the [525 U.S. 116] arresting officer had probable cause to make a custodial arrest, there need not in fact have been a custodial arrest. We granted certiorari, 523 U.S. 1003 (1998), and we now reverse.

The State contends that Knowles has challenged Iowa Code's § 805.1(4) only "on its face" and not "as applied," in which case, the argument continues, his challenge would run afoul of Sibron v. New York, 392 U.S. 40, 20 L. Ed. 2d 917, 88 S. Ct. 1889 (1968).But in his motion to suppress, Knowles argued that "because the officer had no probable cause and no search warrant, and the search cannot otherwise be justified under the Fourth Amendment, the search of the car was unconstitutional." App. 7. Knowles did not argue below, and does not argue here, that the statute could never be lawfully applied. The question we therefore address is whether the search at issue, authorized as it was by state law, nonetheless violates the Fourth Amendment. 2

In Robinson, supra, we noted the 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...

To continue reading

Request your trial
761 practice notes
  • Evans v. Solomon, No. 06-CV-3284 (SLT)(LB).
    • United States
    • United States District Courts. 2nd Circuit. United States District Court (Eastern District of New York)
    • January 19, 2010
    ..."whenever it is lawful for police to detain an automobile and its occupants pending inquiry into a vehicular violation"); Knowles v. Iowa, 525 U.S. 113, 117, 119 S.Ct. 484, 142 L.Ed.2d 492 (1998) ("A routine traffic stop is a relatively brief encounter and `is more analogous to a so-called ......
  • United States v. Ramos, No. CR 15-3940 JB
    • United States
    • United States District Courts. 10th Circuit. District of New Mexico
    • July 11, 2016
    ...investigation of that violation." Rodriguez v. United States, ––– U.S. ––––, 135 S.Ct. 1609, 191 L.Ed.2d 492 (2015). See Knowles v. Iowa, 525 U.S. 113, 117, 119 S.Ct. 484, 142 L.Ed.2d 492 (1998) (observing that the investigation into the traffic offense is "a relatively brief encounter" tha......
  • U.S. v. Hrasky, No. 05-2111.
    • United States
    • United States Courts of Appeals. United States Court of Appeals (8th Circuit)
    • July 18, 2006
    ...elected merely to issue a citation, whether a search incident to the initial arrest would have been unauthorized. Cf. Knowles v. Iowa, 525 U.S. 113, 118-19, 119 S.Ct. 484, 142 L.Ed.2d 492 (1998) (holding that "search incident to citation" violated Fourth Amendment). It was only after Hrasky......
  • People v. Nottoli, Nos. H035902
    • United States
    • California Court of Appeals
    • September 26, 2011
    ...for the authority to search were officer safety and preservation of evidence. ( Id. at p. 763, 89 S.Ct. 2034; see Knowles v. Iowa (1998) 525 U.S. 113, 116–117, 119 S.Ct. 484, 142 L.Ed.2d 492 [There are “ two historical rationales for the ‘search incident to arrest’ exception: (1) the need t......
  • Request a trial to view additional results
738 cases
  • State v. PAUL T., No. 24492.
    • United States
    • New Mexico Supreme Court of New Mexico
    • August 31, 1999
    ...his pockets, and that he would destroy such evidence, is too remote to justify a full-blown search of Paul's person. Cf. Knowles v. Iowa, 525 U.S. 113, 119 S.Ct. 484, 488, 142 L.Ed.2d 492 (1998) (holding search of a speeding motorist unreasonable where "[n]o further evidence of excessi......
  • Reittinger v. Com., Record No. 0246-97-3.
    • United States
    • May 25, 1999
    ...416, 429 S.E.2d 211 (1993). Officer safety is among those interests against which personal rights must be balanced. See Knowles v. Iowa, 525 U.S. 113, ___-___, 119 S.Ct. 484, 487-88, 142 L.Ed.2d 492 (1998) (citing Terry v. Ohio, 392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968)); Maryland v.......
  • State v. Hardaway, No. 99-626.
    • United States
    • Montana United States State Supreme Court of Montana
    • December 10, 2001
    ...467. ¶ 29 Robinson has been consistently followed in subsequent United States Supreme Court decisions. See, e.g., Knowles v. Iowa (1998), 525 U.S. 113, 119 S.Ct. 484, 142 L.Ed.2d 492 (where the Court distinguished a vehicle search incident to the issuance of a traffic citation from a search......
  • State v. Floyd, No. 2015AP1294-CR
    • United States
    • United States State Supreme Court of Wisconsin
    • July 7, 2017
    ...a relatively brief encounter and ‘is more analogous to a so-called Terry [5 ] stop ... than to a formal arrest.’ " Knowles v. Iowa , 525 U.S. 113, 117, 119 S.Ct. 484, 142 L.Ed.2d 492 (quoting Berkemer v. McCarty , 468 U.S. 420, 439, 104 S.Ct. 3138, 82 L.Ed.2d 317 (1984) ) (footnote add......
  • Request a trial to view additional results
1 books & journal articles
  • The Rehnquist Court and Criminal Justice
    • United States
    • Journal of Contemporary Criminal Justice Nbr. 19-2, May 2003
    • May 1, 2003
    ...term on the SupremeCourt: The impact of a new justice. Judicature,75, 238-243.Jones v. United States, 526 U.S. 227 (1999).Knowles v. Iowa, 525 U.S. 113 (1998).Kyllo v. United States, 533 U.S. 27 (2001).Leo, R. (1996). Miranda’s revenge: Police interrogationas a confidence game. Lawand Socie......

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT