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Knowles v. Iowa, 525 U.S. 113 (1998)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Knowles v. Iowa, 525 U.S. 113 (1998)
Knowles v. Iowa No. 97-7597 Argued November 3, 1998 Decided December 8, 1998 525 U.S. 113
CERTIORARI TO THE SUPREME COURT OF IOWA
Syllabus
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. 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. Held: the search at issue, authorized as it was by state law, nonetheless violates the Fourth Amendment. Neither of the two historical exceptions for the "search incident to arrest" exception, see Robinson, supra, at 234, is sufficient to justify the search in the present case. First, the threat to officer safety from issuing a traffic citation is a good deal less than in the case of a custodial arrest. While concern for safety during a routine traffic stop may justify the "minimal" additional intrusion of ordering a driver and passengers out of the car, it does not, by itself justify, the often considerably greater intrusion attending a full field-type search. Even without the search authority Iowa urges, officers have other, independent bases to search for weapons and protect themselves from danger. Second, the need to discover and preserve evidence does not exist in a traffic stop, for, once Knowles was stopped for speeding and issued a citation, all evidence necessary to prosecute that offense had been obtained. Iowa’s argument that a "search incident to citation" is justified because a suspect may try to hide evidence of his identity or of other crimes is unpersuasive. An officer may arrest a driver if he is not satisfied with the identification furnished, and the possibility that an officer would stumble onto evidence of an unrelated offense seems remote. Pp. 116-119.
569 N.W.2d 601 reversed and remanded.
REHNQUIST, C. J., delivered the opinion for a unanimous Court.
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Chicago: U.S. Supreme Court, "Syllabus," Knowles v. Iowa, 525 U.S. 113 (1998) in 525 U.S. 113 525 U.S. 114. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=I6QEM71NHPBE1J9.
MLA: U.S. Supreme Court. "Syllabus." Knowles v. Iowa, 525 U.S. 113 (1998), in 525 U.S. 113, page 525 U.S. 114. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=I6QEM71NHPBE1J9.
Harvard: U.S. Supreme Court, 'Syllabus' in Knowles v. Iowa, 525 U.S. 113 (1998). cited in 1998, 525 U.S. 113, pp.525 U.S. 114. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=I6QEM71NHPBE1J9.
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