Tuesday, November 5, 2013

Knowles v. Iowa case brief

Knowles v. Iowa case brief summary
525 U.S. 113 (1998)

Defendant sought review of a decision of the Iowa Supreme Court that affirmed the denial of defendant's motion to suppress and defendant's conviction on controlled substance charges based on a vehicle search incident to a speeding citation.


  • Defendant was stopped by a police officer for speeding and was issued a citation rather than arrested. The officer then conducted a full search of defendant's car, incident to the citation. 
  • The officer found a bag of marijuana and a "pot pipe." 
  • Defendant was then arrested and charged with violation of Iowa state laws dealing with controlled substances. 
  • Defendant made a motion to suppress the evidence because the search was not incident to arrest. 
  • The trial court denied the suppression motion and convicted defendant. 
  • The state supreme court affirmed the conviction.

The United States Supreme Court reversed and remanded, holding that the issuance of the citation did not authorize the officer, consistently with the Fourth Amendment, to conduct a full search of the car. There was no need to discover and preserve evidence because once defendant was stopped and issued a citation all the evidence necessary to prosecute had been obtained. The threat to safety from issuing a traffic citation was significantly less than in the case of a custodial arrest.


The Court reversed the judgment and remanded for further proceedings.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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