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Knowles v. Iowa
Supreme Court of United States (1998)
Petitioner/Defendant: Knowles; the defendant was speeding and the officer issued him a citation, even though under Iowa law he could have arrested the defendant. Then the officer conducted a full search of the car. The officer did not have any probable cause and he only depended on an Iowa statue which gave officers the right to conduct full search of the vehicle incident to a citation. The officer found marijuana and the defendant was convicted. Now he appeals.
Issue: Does an officer have the right to conduct a search of the vehicle under the 4th Amendment when he is only issuing a citation?
Holding: No
Key Facts: In United States v. Robinson, the court gave the officers the power to search the vehicles incident to a lawful arrest. This served the purpose of officer safety and protection of evidence. This is a 'Bright Line' rule.
Legal Reasoning: The court stated that the concern of officer safety is considerable less when it comes to citation cases compared to arrest cases. The court further reasoned that the threat of destruction of evidence is also considerably less in citatin cases. So the court ruled that it was not ready to extend the Robinson rule to citation cases and the conviction was reversed.