Knowles v. Iowa

LOCATION: Knowles' Car

DOCKET NO.: 97-7597
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: Iowa Supreme Court

CITATION: 525 US 113 (1998)
ARGUED: Nov 03, 1998
DECIDED: Dec 08, 1998

Bridget A. Chambers - Argued the cause for the respondent
Paul Rosenberg - Argued the cause for the petitioner

Facts of the case

After stopping him for speeding, an Iowa police officer issued Patrick Knowles a citation and conducted a full search of his car without probable cause or Knowles' consent. When his search turned up a "pot pipe" and some marijuana, the officer arrested Knowles on state drug charges. Knowles challenged these on grounds that because he was not arrested at any time prior to the search, the search was unconstitutional. On appeal from consecutive adverse rulings in lower courts, the Supreme Court granted Knowles certiorari.


Can a search of a stopped vehicle that occurs prior to the driver's arrest be sustained under the "search incident to arrest" exception that permits officers to search stopped vehicles without first obtaining a search warrant?

Media for Knowles v. Iowa

Audio Transcription for Oral Argument - November 03, 1998 in Knowles v. Iowa

William H. Rehnquist:

We'll hear argument next in No. 97-7597, Patrick Knowles v. Iowa.

Mr. Rosenberg.

Paul Rosenberg:

Mr. Chief Justice, and may it please the Court:

By statute in Iowa, police are authorized to search any motor vehicle in which the driver receives a traffic citation.

The question presented here is whether Iowa's search incident citation statute shall be adopted by this Court as a new category of per se reasonable searches.

It was in March of 19--

Sandra Day O'Connor:

I'm not sure that's what the statute does.

The statute says, I believe, the issuance of a citation in lieu of arrest or in lieu of continued custody does not affect the officer's authority to conduct an otherwise lawful search.

So, I took it that the issue was whether this was a lawful search, not whether the statute said there can be a full-blown search.

I thought it left it to the subsequent determination of whether the search was lawful.

Now, in this case, the Iowa court said that a full search was lawful but, in the course of that, seemed to rely, at least in part, on Federal law under the Fourth Amendment.

Paul Rosenberg:

--Well, the Iowa Supreme Court has construed this language that says otherwise lawful search to extend the search incident to... excuse me... search incident to arrest exception to encompass those circumstances where a citation is issued and there is in fact--

Sandra Day O'Connor:

Well, I thought what the court below did was to say that a full search on the occasion of a traffic citation was lawful in their view.

Isn't that what happened?

Paul Rosenberg:


Yes, they did say that.

Sandra Day O'Connor:


It isn't that the statute requires that result.

They said that kind of a search is lawful.

So, I guess what we have to decide is whether under the Federal Constitution that's correct.

Paul Rosenberg:

That's correct, Your Honor.

In March of 1996, Mr. Knowles was pulled over for speeding in Newton, Iowa.

In all respects, this was a routine traffic encounter.

Mr. Knowles was obedient to the single deterrent to pull over.

He produced a valid driver's license.

A computer check revealed that there were no warrants for his arrest, and the police officer testified that he had no suspicion--

Ruth Bader Ginsburg:

Mr. Rosenberg, could you just back up for a minute because in your answer to Justice O'Connor, you said something that I didn't understand you had challenged.

That is, I didn't understand that you had contested the authority to make a full custodial arrest for speeding.

You had only contested that if they don't and they merely give him a citation, then they can't search.

But I hadn't realized that you had raised the question that Justice Stewart left over in the Gustafson case, which was whether you could have constitutionally a full arrest for a traffic violation.