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Court Opinions ›› Knowles v. Iowa (1998)
PATRICK KNOWLES, PETITIONER v. IOWA
No. 97-7597 SUPREME COURT OF THE UNITED STATES 525 U.S. 113; 119 S. Ct. 484; 142 L. Ed. 2d 492; 1998 U.S. LEXIS 8068; 67 U.S.L.W. 4027; 98 Daily Journal DAR 12417; 1998 Colo. J. C.A.R. 6164 November 3, 1998, Argued December 8, 1998, Decided SUBSEQUENT HISTORY: As Amended October 21, 1999. PRIOR HISTORY: ON WRIT OF CERTIORARI TO THE SUPREME COURT OF IOWA. 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, 414 U.S. 218, 38 L. Ed. 2d 427, 94 S. Ct. 467. 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.
The search at issue, authorized as it was by state law, nonetheless violates the Fourth Amendment.
...[W]e held that the authority to conduct a full field search as incident to an arrest was a "bright-line rule," which was based on the concern for officer safety and destruction or loss of evidence, but which did not depend in every case upon the existence of either concern. Here we are asked to extend that "bright-line rule" to a situation where the concern for officer safety is not present to the same extent and the concern for destruction or loss of evidence is not present at all. We decline to do so.
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