Knowles, Patrick v. Iowa (12/08/1998)

By: Jamie Paton, Medill News Service

Questions presented

Whether police searches of vehicles on routine traffic stops constitute an ""unreasonable search and seizure.""

Brief

Patrick Knowles was pulled over for speeding in Newton, Iowa. There was no evidence of a crime, and police officer Ronald Cook later admitted in trial that he had no reason at all to suspect Knowles had committed one. It was simply routine.

A little more investigation, and there was still no cause for alarm. After checking Knowles' driver's license, Cook concluded there were no outstanding arrest warrants.

Yet after giving Knowles a ticket, Cook exercised an authority that state law gave him: he began a thorough search of Knowles' car.

The search which may not have been permissible in many states turned up some marijuana and a pipe, and Knowles was promptly arrested.

Knowles' attorney objected at trial to the introduction of evidence of marijuana, arguing that the officer did not have probable cause to search his car. An Iowa law undermined his constitutional protection from unreasonable searches, a right deeply rooted in the Fourth Amendment, Knowles argued.

Iowa state law gives police officers blanket authority to search a vehicle after a motorist has been stopped for just about anything.

With four judges dissenting, a divided Iowa Supreme Court held that under Iowa law, speeding is grounds for arrest, and that is enough to warrant a search.

""When an officer acquires grounds for searching a suspect's person or automobile in the absence of probable cause, an election by the officer to pursue a lesser intrusion, such as issuing a citation, may be conditioned on certain aspects of detention and search that are conducive to the officer's safety,"" the Iowa Supreme Court held.

One of the nation's most influential police organizations has highlighted the case, underscoring the perils that police officers face when pulling people over. The National Association of Police Organizations, an advocacy group representing more than 4,000 police unions and associations, filed an amicus brief in late June.

""Traffic stops are inherently dangerous and risky and pose a significant threat to the physical safety of law enforcement officers. Stopping a motor vehicle constitutes one of the least predictable and potentially most dangerous duties of a law enforcement officer.""

The U.S. Supreme Court granted certiorari on March 23, 1998.

On Dec. 8, 1998, a unanimous Supreme Court held that the search, authorized as it was by state law, nonetheless violated the 4th Amendment. Writing for the court, Chief Justice William Rehnquist found that neither of the two historical exceptions for the ""search incident to arrest"" exception, was sufficient to justify the search. First, the threat to officer safety from issuing a traffic citation is a good deal less than in the case of acustodial arrest. 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.