Knowles v. Iowa 525 U.S. 113, 119 S. Ct. 484, 142 L. Ed.2d 492 (1998)
The police pulled Knowles over
for speeding. They gave him a ticket, but did not arrest him.
The policeman then proceeded
to search Knowles' vehicle and found drugs. Knowles was arrested for drug
The Trial Court convicted
Knowles of drug possession. He appealed.
Knowles argued that the
warrantless search of his vehicle was an unconstitutional violation of
his 4th Amendmentright
The police argued that it
was a permissible search since it was a search incident to a lawful
A SILA is justified because
people under arrest sometimes get violent or try to destroy evidence.
See United States v.
Robinson (414 U.S. 218 (1973)).
The Iowa Supreme Court upheld
the conviction. Knowles appealed.
The Iowa Supreme Court found
that under Iowa State law (Iowa Code Ann. §321.485(1)(a)) the police have the option of
arresting someone for a traffic violation, therefore the search was
legal, even though they didn't actually arrest Knowles.
The US Supreme Court
overturned the conviction.
The US Supreme Court found
that given the type of stop, there were no grounds for the policeman to
believe that his safety was in jeopardy or that there was evidence in
danger of being destroyed. Therefore he had no probable cause to perform a search without Knowles consent.
"Once Knowles was
stopped for speeding and issued a citation, all the evidence necessary
to prosecute that offense had been obtained. 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."
Also, since Knowles was not
"in custody", there was no custodial exception to permit a
It might still be possible to
justify the search on the basis of police officer safety. Sometimes
people get violent when pulled over, even if they are not actually getting