An officer on patrol stopped a vehicle for a traffic infraction after receiving information that the vehicle’s occupants might have been involved in a drug sale. After initially interacting with the driver, the officer waited for backup before removing the occupants and conducting a search with a drug-sniffing dog, which led to the discovery of a gun. The passenger, Tyre Brown, admitted ownership of the gun and was charged with unlawful possession of a firearm. Brown argued that the officer unlawfully prolonged the stop beyond the time necessary to address the traffic infraction, violating his constitutional rights.

The Iowa Supreme Court reviewed the case and held that the shared-knowledge doctrine allowed the officer to act on information provided by another officer who had observed a potential drug transaction, thus justifying the extension of the stop. The court found that the extension of the stop to investigate for drugs did not violate Brown’s constitutional rights

Iowa v. Brown

Citizen sought to access “Use of Force” reports form the Des Moines Police Department. The City of Des Moines argued that these reports are confidential to which the Iowa District for Polk County supported the citizen and advised that these reports are not exempt as they contain factual information about incidents.

The Iowa Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the use of force reports are not exempt from disclosure under section 22.7(11) as they are factual reports, not confidential personnel records. The City of Des Moines was allowed to redact information that pertained to injuries or officers medical attention.

Harrison v. Mickey

An Iowa State Patrol trooper stopped a vehicle for speeding. During the stop, the trooper smelled marijuana and conducted a warrantless search of the vehicle, finding marijuana in a backpack in the trunk. The driver was charged with possession of marijuana with intent to deliver and failure to affix a drug tax stamp. A motion to suppress was filed as the defendant believed the search was unconstitutional.

Iowa District Court and the Iowa Supreme Court the considered McClain’s argument to abandon the automobile exception to the warrant requirement. The court reaffirmed its previous decision in State v. Storm, which upheld the automobile exception, noting that the justifications for the exception, including the inherent mobility of vehicles and the lower expectation of privacy in vehicles, remain valid. The court concluded that the availability of electronic search warrants does not undermine the rationale for the automobile exception.

Iowa v. McClain

Defendant was seized and search where officers located cash and narcotics on her person/belongings. Defendant filed motion to suppress and that the traffic stop, search and seizure were unlawful. Defendant also argued she was charged incorrectly as her sentencing was for previous listed convictions.

Iowa Court of Appeals and Iowa Supreme Court both ruled that the traffic stop and search were lawful based on search incident to arrest. The courts also affirmed that her sentencing was illegal as her previous convictions fell under a different code section. The Iowa Supreme Court remanded the case for resentencing.

Iowa v. Gale

Defendant was arrested for OWI and taken to the jail where she was given her phone and informed of her rights, including her right to contact an attorney, but she did not make any attempt to do so. Defendant filed a motion to suppress evidence as she claimed her rights under 804.20 were violated when she was not permitted to contact an attorney.

The Iowa District Court denied the motion and the defendant was found guilty. The defendant filed an appeal in which the Iowa Court of Appeals affirmed the Iowa District Courts decision. The Iowa Supreme Court granted further review and determined that Iowa Code section 804.20 was not violated, as the defendant was given a reasonable opportunity to contact an attorney without unnecessary delay.

Iowa v. Clark

Officers received a tip about narcotics trafficking at a residence. A warrantless search of garbage bags placed curbside for disposal was conducted and evidence consistent with narcotic trafficking was found. The evidence obtained was used to obtain a search warrant for the home in which additional evidence was found which led to the defendants being charged. The defendants moved to suppress the evidence stating that section 808.16 of the Iowa Code is unconstitutional.

The Iowa District Court for Polk Count ruled in favor of the defendants declaring Iowa Code section 808.16 facially unconstitutional under article I, section 8 of the Iowa Constitution, as interpreted in State v. Wright. The State of Iowa filed an appeal on this decision. The Iowa Supreme Court reviewed the case and concluded that the district court erred in its ruling. The court held that the specific provision in Iowa Code section 808.16(3), which deems garbage placed outside for collection in a publicly accessible area as abandoned property, is constitutional both facially and as applied in this case. This provision preempts conflicting local ordinances and negates any reasonable expectation of privacy in such garbage. Consequently, the warrantless trash pulls conducted by the police were lawful, and the evidence obtained was admissible. The Iowa Supreme Court reversed the district court’s suppression ruling and remanded the case for further proceedings consistent with its opinion.

Iowa v. Amble

Defendant was charged with possession of a controlled substance after police officers found methamphetamine in his fanny pack during a search incident to his arrest on unrelated charges. Defendant attempted to pass the fanny pack to another person before being handcuffed. He argued that the search violated his constitutional rights because he could no longer access the fanny pack at the time it was searched. Defendant filed a motion to suppress, claiming he did not have access to the fanny pack.

– The Iowa District Court for Black Hawk County denied Scullark’s motion to suppress the evidence, finding the search valid as a search incident to arrest. Scullark entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The Iowa Court of Appeals reversed the district court’s decision, agreeing with Scullark that the search did not satisfy the search incident to arrest (SITA) exception because he could not access the fanny pack at the time it was searched. – The Iowa Supreme Court reviewed the case and vacated the court of appeals decision, affirming the district court’s order. The court held that the search of the fanny pack was valid under both the United States Constitution and the Iowa Constitution. The court concluded that because the fanny pack was worn around Scullark’s waist at the time of his arrest, it was considered part of his person. Therefore, the search was justified as a search of his person incident to a lawful arrest, requiring no additional justification. The court emphasized that the SITA exception allows for a full search of the arrestee’s person and items immediately associated with the person.

Iowa v. Scullark

During a traffic stop, Defendant was found in possession of drugs, a scale, a loaded semiautomatic pistol, and additional high-capacity firearm magazines. He was charged with possession of a controlled substance and carrying a dangerous weapon while in the illegal possession of a controlled substance or while committing an indictable offense. The Defendant pleaded guilty but challenged the latter conviction as violation of his 2nd Amendment rights and of the Iowa Constitution.

– The Iowa District Court for Polk County denied Woods’s motion to dismiss the dangerous weapon charge, reasoning that the legislature could impose reasonable time, place, and manner restrictions on the right to keep and bear arms. The court concluded that the prohibition on carrying firearms while illegally possessing a controlled substance or committing an indictable offense was a reasonable regulation. – The Iowa Supreme Court reviewed the case and affirmed the lower court’s decision. The court held that the Second Amendment does not cover the right to carry a firearm while illegally possessing a controlled substance or committing an indictable offense. The court reasoned that the federal constitutional right to keep and bear arms is limited to responsible, law-abiding citizens engaged in lawful conduct.

Iowa v. Woods

The Defendant consented to a one-year protective order in a domestic abuse case, which prohibited him from possessing firearms under Iowa Code section 724.26(2)(a). Despite this, Defendant pawned stolen firearms while the order was in effect. He was charged with theft and violations of section 724.26(2)(a). The theft charge was dropped, and he was convicted of two violations of section 724.26(2)(a). Defendant appealed convictions and stated it was a violation of his 2nd Amendment rights.

– Iowa District Court for Story County denied his motion to dismiss based on constitutional claims. – The Iowa Supreme Court reviewed the case and held that Cole waived his Second Amendment and article I, section 1A rights by consenting to the protective order, which explicitly prohibited firearm possession.

Iowa v. Cole

The Defendant consented to a one-year protective order in a domestic abuse case, which prohibited him from possessing firearms under Iowa Code section 724.26(2)(a). Despite this, Defendant pawned stolen firearms while the order was in effect. He was charged with theft and violations of section 724.26(2)(a). The theft charge was dropped, and he was convicted of two violations of section 724.26(2)(a). Defendant appealed convictions and stated it was a violation of his 2nd Amendment rights.

– Iowa District Court for Story County denied his motion to dismiss based on constitutional claims. – The Iowa Supreme Court reviewed the case and held that Cole waived his Second Amendment and article I, section 1A rights by consenting to the protective order, which explicitly prohibited firearm possession.

Iowa v. Meisheid

Police officer continued motorcycle chase after it was terminated by Iowa State Patrol.Speeds reached 100mph through the City and neighborhoods. The chase proceeded onto a county road where the polcie cruiser struck the motorcycle leading to serious injuries that would later become fatal. Family of the plaintiff filed claims including constitutional violations, and assault and battery. The district court dismissed the constitutional claims but allowed the assault and battery claims to proceed to trial. A jury found the police officer liable and awarded $4.25 million in compensatory damages, and $10,000 in punitive damages. The courts denied motions for a new trial.

– The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that emergency response immunity under Iowa law does not shield a municipality or its officer from liability when the officer acts with reckless disregard for safety, as found by the jury. The court also concluded that the assault and battery claims were sufficiently pleaded under Iowa’s notice pleading standard, that there was substantial evidence to support the jury’s verdicts, and that the admission of the decedent’s dying declaration and evidence regarding police recording policies was proper. The punitive damages award was also upheld. – Testimony from fellow officers and the State Trooper who initiated that chase ultimately provided evidence determining there was a safety concern with continuing the chase. The police officer also failed to inititate his bodyworn camera or dash mounted camera during the pursuit.

Mormann v. City of Manchester, IA