The United States Supreme Court today reversed the decision of the Iowa Supreme Court in the case of Knowles v. Iowa. In a unanimous opinion the U.S. Supreme Court ruled that the "search incident to arrest" doctrine, which authorizes the search of drivers and the interiors of their cars following an arrest, does not apply to traffic stops when the driver is released on citation rather than arrested.
For more than ten years a little-used provision of Iowa law has permitted the search of persons who were subject to arrest but who were instead released following issuance of a citation. The Supreme Court ruling means that, at least in traffic stops where there is no concern with officer safety or the preservation of evidence, officers who issue citations may not search drivers and the interior of their automobiles.
The opinion is not expected to have a big impact on the day-to-day operations of police officers in Iowa, since officers have rarely used the "search incident to citation" procedure in the past. The Supreme Court opinion makes it clear that officers have other procedures available if they are concerned for their safety. For example, police can order drivers and their passengers to exit their vehicles. Police can "pat down" drivers or passengers if there is reasonable suspicion that they are armed and dangerous. Also, police have authority in Iowa to arrest drivers, even for simple misdemeanor offenses, thereby allowing "search incident to arrest."
No statutory change is anticipated in Iowa as a result of the opinion. The Iowa Code provides that issuance of a citation instead of arrest does not affect an officer's authority to conduct "an otherwise lawful search." The opinion clarifies that a search in conjunction with a citation for a traffic offense - where there is no concern for officer safety or need for preservation of evidence - is not lawful.
The opinion remands the Knowles case to the Iowa court. Since the U.S. Supreme Court did not address the issue of "good faith" exception to the exclusionary rule, it is anticipated that issue will now be addressed in the Iowa courts.