We have recognized that the first rationale-officer safety-is "'both legitimate and weighty,'" Maryland v. Wilson, 519 U. S. 408, 412 (1997) (quoting Pennsylvania v. Mimms, 434 U. S. 106, 110 (1977) (per curiam)). He argued that the search could not be sustained under the "search incident to arrest" exception recognized in United States v. Robinson, 414 U. S. 218 (1973), because he had not been placed under arrest. 97-7597. REHNQUIST, C. J., delivered the opinion for a unanimous Court. Relying on its earlier opinion in State v. Doran, 563 N. W. 2d 620 (1997), the Iowa Supreme Court upheld the constitutionality of the search under a bright-line "search incident to citation" exception to the Fourth Amendment's warrant requirement, reasoning that so long as the. But neither of these underlying rationales for the search incident to arrest exception is sufficient to justify the search in the present case. CHIEF JUSTICE REHNQUIST delivered the opinion of the Court. 1997). . [are] sufficient.” For the former, the court reasoned that “a routine traffic stop . Berkemer v. McCarty, 468 U. S. 420, 439 (1984). 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. 6164 (U.S. Dec. 8, 1998). 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.
An Iowa policeman stopped petitioner Knowles for speeding and issued him a citation rather than arresting him. 7. . Issue. See also Cupp v. Murphy, 412 U. S. 291, 296 (1973) ("Where there is no formal arrest ... a person might well be less hostile to the police and less likely to take conspicuous, immediate steps to destroy incriminating evidence"). . Paul Rosenberg argued the cause for petitioner.
With her on the brief were Thomas J. Miller, Attorney General, and Elizabeth M. Osenbaugh, Solicitor General. See §811.1 (West Supp. See Mimms, supra, at 110; Wilson, supra, at 413-414. Held: The search at issue, authorized as it was by state law, nonetheless violates the Fourth Amendment.
. 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. 977597. 1996). 525 U.S. 113, 119 S.Ct. He relied on Iowa law dealing with such searches. 414 U. S., at 234.
arresting officer had probable cause to make a custodial arrest, there need not in fact have been a custodial arrest. We recognized that "[t]he danger to the police officer flows from the fact of the arrest, and its attendant proximity, stress, and uncertainty, and not from the grounds for arrest." Argued November 3, 1998-Decided December 8,1998. Agnello v. United States, 269 U. S. 20, 30 (1925); Weeks v. United States, 232 U. S. 383, 392 (1914). KNOWLES v. IOWA. No. is a relatively brief encounter.” For the latter, the court argued that once the respondent was issued a citation “all the evidence necessary to prosecute that offense has been obtained. 97—7597. Once Knowles was stopped for speeding and issued a citation, all the evidence necessary to prosecute that offense had been obtained. The police officer issued a citation to Knowles, although under Iowa law he might have arrested him. A police officer pulled over a speeder, issued a citation rather than arrest, and then searched the speeder’s car, finding drugs. may order out of a vehicle both the driver, Mimms, supra, at 111, and any passengers, Wilson, supra, at 414; perform a "patdown" of a driver and any passengers upon reasonable suspicion that they may be armed and dangerous, Terry v. Ohio, 392 U. S. 1 (1968); conduct a "Terry pat down" of the passenger compartment of a vehicle upon reasonable suspicion that an occupant is dangerous and may gain immediate control of a weapon, Michigan v. Long, 463 U. S. 1032, 1049 (1983); and even conduct a full search of the passenger compartment, including any containers therein, pursuant to a custodial arrest, New York v. Belton, 453 U. S. 454, 460 (1981).
Justia Annotations is a forum for attorneys to summarize, comment on, and analyze case law published on our site. 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 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. An Iowa police officer stopped petitioner Knowles for speeding, but issued him a citation rather than arresting him. The court cited two historical rationales for the search incident to arrest exception: (1) the need to disarm the suspect in order to take him into custody, and (2) the need to preserve evidence for later use at trial.” The court concluded that “neither of these rationales .
is a relatively brief encounter.” For the latter, the court argued that once the respondent was issued a citation “all the evidence necessary to prosecute that offense has been obtained. Pp. No. An officer issuing a traffic citation cannot search the cited person’s vehicle.
36. Knowles was then arrested and charged with violation of state laws dealing with controlled substances. The State contends that Knowles has challenged Iowa Code's § 805.1(4) only "on its face" and not "as applied," in which case, the argument continues, his challenge would run afoul of Sibron v. New York, 392 U. S. 40 (1968). 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. Synopsis of Rule of Law. 97-7597. The question presented is whether such a procedure authorizes the officer, consistently with the Fourth Amendment, to conduct a full search of the car.
. No.
Pp. The Supreme Court of Iowa, sitting en bane, affirmed by a divided vote. As for the destruction of evidence relating to identity, if a police officer is not satisfied with the identification furnished by the driver, this may be a basis for arresting him rather than merely issuing a citation.
neither Knowles' consent nor probable cause to conduct the search. See 3 W. LaFave, Search and Seizure § 5.2(h), p. 99, and n. 151 (3d ed. A routine traffic stop, on the other hand, is a relatively brief encounter and "is more analogous to a so-called 'Terry stop' ... than to a formal arrest." Even without the search authority Iowa urges, officers have other, independent bases to search for weapons and protect themselves from danger. The judgment of the Supreme Court of Iowa is reversed, and the cause is remanded for further proceedings not inconsistent with this opinion. But while the concern for officer safety in this context 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 fieldtype search. For example, they. Iowas 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. Here we. The search was authorized by Iowa law even though there was no arrest. Justia makes no guarantees or warranties that the annotations are accurate or reflect the current state of law, and no annotation is intended to be, nor should it be construed as, legal advice. . The search was authorized by Iowa law even though there was no arrest. 492, Held. as amici curiae urging reversal. An Iowa policeman stopped petitioner Knowles for speeding and issued him a citation rather than arresting him. App. In Robinson, supra, we noted the two historical rationales for the "search incident to arrest" exception: (1) the need to disarm the suspect in order to take him into custody, and (2) the need to preserve evidence for later use at trial.
KNOWLES v. IOWA(1998) No. Contacting Justia or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship. The Iowa Supreme Court has interpreted this provision as providing authority to officers to conduct a fullblown search of an automobile and driver in those cases where police elect not to make a custodial arrest and instead issue a citation-that is, a search incident to citation. Nor has Iowa shown the second justification for the authority to search incident to arrest-the need to discover and preserve evidence. The court cited two historical rationales for the search incident to arrest exception: (1) the need to disarm the suspect in order to take him into custody, and (2) the need to preserve evidence for later use at trial.” The court concluded that “neither of these rationales . With him on the briefs was Maria Ruhtenberg. Knowles did not argue below, and does not argue here, that the statute could never be lawfully applied. Every Bundle includes the complete text from each of the titles below: PLUS: Hundreds of law school topic-related videos from The Understanding Law Video Lecture Series™: Monthly Subscription ($19 / Month) Annual Subscription ($175 / Year). But in his motion to suppress, Knowles argued that "[b]ecause the officer had no probable cause and no search warrant, and the search cannot otherwise be justified under the Fourth Amendment, the search of the car was unconstitutional." 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.
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