Knowles v. Iowa
525 U.S. 113, 119 S. Ct. 484, 142 L. Ed.2d 492 (1998)

  • The police pulled Knowles over for speeding. They gave him a ticket, but did not arrest him.
  • The policeman then proceeded to search Knowles’ vehicle and found drugs. Knowles was arrested for drug possession.
  • The Trial Court convicted Knowles of drug possession. He appealed.
    • Knowles argued that the warrantless search of his vehicle was an unconstitutional violation of his 4th Amendment right to privacy.
    • The police argued that it was a permissible search since it was a search incident to a lawful arrest (SILA).
      • A SILA is justified because people under arrest sometimes get violent or try to destroy evidence.
      • See United States v. Robinson (414 U.S. 218 (1973)).
  • The Iowa Supreme Court upheld the conviction. Knowles appealed.
    • The Iowa Supreme Court found that under Iowa State law (Iowa Code Ann. §321.485(1)(a)) the police have the option of arresting someone for a traffic violation, therefore the search was legal, even though they didn’t actually arrest Knowles.
  • The US Supreme Court overturned the conviction.
    • The US Supreme Court found that given the type of stop, there were no grounds for the policeman to believe that his safety was in jeopardy or that there was evidence in danger of being destroyed. Therefore he had no probable cause to perform a search without Knowles consent.
      • “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.”
    • Also, since Knowles was not “in custody”, there was no custodial exception to permit a search either.
  • It might still be possible to justify the search on the basis of police officer safety. Sometimes people get violent when pulled over, even if they are not actually getting arrested.