Knowles v. Iowa
| Knowles v. Iowa | |
|---|---|
 | |
| Holding | |
| A law enforcement officer may not search a person's vehicle without their consent when they are not in custody once they have been cited without violating the Fourth Amendment prohibition on unreasonable searches and seizures. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Rehnquist, joined by unanimous |
| Laws applied | |
| Iowa Code §321.485(1)(a); U.S. Const. amend. IV | |
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 for the offense.[1]
Background
Patrick Knowles was stopped in
Before trial, Knowles argued the search was not applicable to the "search incident to arrest" exception recognized in United States v. Robinson,[2] 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
A divided Iowa Supreme Court upheld the search and the conviction.[3]
Supreme Court
The U.S. Supreme Court decided that the search was unlawful.
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.
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.
See also
- List of United States Supreme Court cases, volume 525
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
Further reading
- Gillespie, Daniel T. (1999). "Bright-Line Rules: Development of the Law of Search and Seizure during Traffic Stops". Loyola University Chicago Law Journal. 31: 1.
References
- ^ Knowles v. Iowa, 525 U.S. 113 (1998)
This article incorporates public domain material from this U.S government document.
- ^ United States v. Robinson, 414 U.S. 218 (1973).
- ^ State v. Knowles, 569 N.W.2d 601 (Iowa 1997).
External links
- Text of Knowles v. Iowa, 525 U.S. 113 (1998) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)