Patrick Knowles Case Brief
Date/Court: The United States Supreme Court, 1998
Facts: This case deals with the defendant Patrick Knowles; who was stopped in Newton, Iowa for driving 20 miles over the speed limit. The police officer at the time pulled Knowles over and issued him a ticket, but under the Iowa Code the officer could have arrested the individual. After writing Knowles a ticket the officer searched the vehicle, where under the driver’s seat he found a pipe that could be used to smoke Marijuana and a small bag of marijuana. Upon finding these two items Knowles was arrested and charged with having a controlled substance. At pre-trial, Knowles moved to suppress the marijuana and pipe from court. He claimed that the search was a violation of his rights and that
it could not be sustained under the search incident to arrest. The Iowa court disagreed citing in Section 805 of the Iowa Code that a citation in lieu of a arrest in return does not change the officer’s ability to conduct a search. Knowles disagreed with this and ultimately the Supreme Court took the case.
Legal Question: Is writing a citation allow cause to search incident to arrest allowing for a lawful search of evidence, or does it violate the 4th Amendment in return making the search illegal?
Legal Answer: The Supreme Court said that a Citation does not allow a search incident to arrest and any evidence found would not be used in court.
Reasoning: There are two requirements for search incident to arrest. The first being that the need to disarm the suspect so that the officer can take him into custody and second is the need to preserve evidence at could be used at trial. In the opinion the court says that a traffic stop is a brief encounter and can still be dangerous, but is not like Terry stops were an individual might be more hostile. The court says that an officer can order the suspects out of the car for his/her safety, but they cannot do a full field search. The Supreme Court also said that once the officer stopped Knowles for going 20 mph over the speed limit all the evidence that need to prosecute Knowles was found and no other evidence of speeding needed to be collected. So the officer did not need to search the vehicle for evidence, the decision is reversed and case is remanded.
Facts: This case deals with the defendant Patrick Knowles; who was stopped in Newton, Iowa for driving 20 miles over the speed limit. The police officer at the time pulled Knowles over and issued him a ticket, but under the Iowa Code the officer could have arrested the individual. After writing Knowles a ticket the officer searched the vehicle, where under the driver’s seat he found a pipe that could be used to smoke Marijuana and a small bag of marijuana. Upon finding these two items Knowles was arrested and charged with having a controlled substance. At pre-trial, Knowles moved to suppress the marijuana and pipe from court. He claimed that the search was a violation of his rights and that
it could not be sustained under the search incident to arrest. The Iowa court disagreed citing in Section 805 of the Iowa Code that a citation in lieu of a arrest in return does not change the officer’s ability to conduct a search. Knowles disagreed with this and ultimately the Supreme Court took the case.
Legal Question: Is writing a citation allow cause to search incident to arrest allowing for a lawful search of evidence, or does it violate the 4th Amendment in return making the search illegal?
Legal Answer: The Supreme Court said that a Citation does not allow a search incident to arrest and any evidence found would not be used in court.
Reasoning: There are two requirements for search incident to arrest. The first being that the need to disarm the suspect so that the officer can take him into custody and second is the need to preserve evidence at could be used at trial. In the opinion the court says that a traffic stop is a brief encounter and can still be dangerous, but is not like Terry stops were an individual might be more hostile. The court says that an officer can order the suspects out of the car for his/her safety, but they cannot do a full field search. The Supreme Court also said that once the officer stopped Knowles for going 20 mph over the speed limit all the evidence that need to prosecute Knowles was found and no other evidence of speeding needed to be collected. So the officer did not need to search the vehicle for evidence, the decision is reversed and case is remanded.