Knowles v. Iowa
525 U.S. 113 (1998)
Author: DK

Facts:  Officer stopped the petitioner for speeding.  Even though the officer could have arrested the petitioner, but he decided to issue a citation.  Then the officer searched the whole car and found marijuana under the driver’s seat.  The officer was following an Iowa law which allowed such searches in cases where only citations were issued but arrests could have been made. 

Procedure:  The Supreme Court of Iowa upheld the law.

Issue:  Can an officer search a car incident to a citation issuance?

Holding: No

Rationale:  The rationale behind the search incident to a lawful arrest is to protect officer’s form arrestees which whom the officers have extended contact and to protect evidence.  In this case, the officer safety concern was dramatically reduced because no arrest was made and only a citation was issued.  Also, the concern for the protection of evidence is nonexistent because once the officer stopped the petitioner, the evidence for speeding crime was already obtained.  Therefore, the bright line rule of Robinson is not extended to cases where only a citation is issued.