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Knowles v. Iowa


The defendant was lawfully stopped and issued a citation for speeding. Under Iowa law, the officer could have either arrested him or followed the more traditional route of issuing a traffic citation. Another section of Iowa law stated that the issuance of a citation in lieu of an arrest does not defeat the officer’s authority to conduct an otherwise lawful search as if the arrest had occurred. The Iowa Supreme Court interpreted this statute as providing law enforcement officers the ability to search any automobile that has been lawfully stopped for a traffic violation. The search conducted pursuant to the defendant’s traffic stop yielded contraband.


Whether officers are justified in conducting searches of automobiles based solely on the fact that it has been stopped for a traffic violation.


No. Law enforcement officers are not justified in conducting searches incident to traffic citations.


The Supreme Court called the Iowa Supreme Court’s interpretation of its statute a “search incident to citation,” a derivative of a search incident to arrest. The Supreme Court stated that a search incident to arrest was a valid exception to the Fourth Amendment’s warrant requirement because of the need to disarm the suspect and to preserve evidence for later use at trial.

The Court dismissed the consideration of officer’s safety in allowing a search incident to citation because it did not believe the issuance of a citation is as dangerous as an arrest. The officer will not spend as much time with the defendant while issuing a citation, stress levels are not as great and the outcome is not as uncertain as during an arrest. The Supreme Court also held that the second rationale for a search incident to arrest, to secure evidence for later use, is not logical because it is unlikely the officer will find additional evidence of the traffic violation by searching the automobile.


525 U.S. 113, 119 S. Ct. 484 (1998)

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