Knowles v. Iowa
Decided on Dec. 8, 1998; 525 U.S. 113


Police searches of vehicles on routine traffic stops constitute "unreasonable search and seizure."

 

I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed:  Search and seizure

B. Legal Question Presented: 

Does issuing a citation for speeding authorize an officer, consistently with the Fourth Amendment, to conduct a full search of a car?

II. CASE SUMMARY:

A. Background:

"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.

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."

On certiorari, the U.S. Supreme Court reversed the judgment of the Supreme Court of Iowa.

B. Counsel of Record:

ACLU Side
(Petitioner/Appellant)

Opposing Side
(Respondent/Appellee)

Unavailable Unavailable
C. The Arguments:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
Unavailable Unavailable
III. AMICI CURIAE:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)

Paul Rosenberg argued the cause for petitioner. With him on the briefs was Maria Ruhtenberg.

James J. Tomkovicz, Steven R. Shapiro, Susan N. Herman, and Lisa B. Kemler filed a brief for the American Civil Liberties Union et al. as amici curiae urging reversal.

Bridget A. Chambers, Assistant Attorney General of Iowa, argued the cause for respondent. With her on the brief were Thomas J. Miller, Attorney General, and Elizabeth M. Osenbaugh, Solicitor General.

Stephen R. McSpadden filed a brief for the National Association of Police Organizations, Inc., as amicus curiae urging affirmance.

IV. THE SUPREME COURT'S DECISION:

The Supreme Court held that:

"The search at issue, authorized as it was by state law, nonetheless violates the Fourth Amendment...

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...

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..."

The United States Supreme Court reversed the Supreme Court of Iowa judgment.

Justice Vote: 9 Pro vs. 0 Con
  • Rehnquist, W. Pro (Wrote majority opinion)
  • Ginsburg, R. Pro (Joined majority opinion)
  • Kennedy, A. Pro (Joined majority opinion)
  • Breyer, S. Pro (Joined majority opinion)
  • Souter, D. Pro (Joined majority opinion)
  • Scalia, A. Pro (Joined majority opinion)
  • Stevens, J. Pro (Joined majority opinion)
  • Thomas, C. Pro (Joined majority opinion)
  • O'Connor, S. Pro (Joined majority opinion)
V. A WIN OR LOSS FOR THE ACLU?

The ACLU, as amicus curiae, urged reversal of the judgment of the Supreme Court of Iowa; the Supreme Court reversed in a 9-0 vote, giving the ACLU an apparent win.