Aurelio Javier Ortiz v. State of Iowa, 16-0441

On November 25, 2012, Des Moines police stopped Ortiz for lack of a front license plate, smelled marijuana, and searched the vehicle; officers found marijuana, methamphetamine, paraphernalia, and a handgun.
State charges were filed in Iowa; federal charges (felon in possession / illegal transfer of firearms) were also filed arising from the same incident.
Ortiz pleaded guilty in state court to possession with intent to deliver methamphetamine; he did not file a suppression motion in state court and received a 45-year sentence (15-year mandatory minimum).
In federal court Ortiz moved to suppress the vehicle search; that motion was denied and the denial was affirmed on appeal.
Ortiz sought postconviction relief in Iowa, claiming trial counsel was ineffective for failing to file a state-constitutional suppression motion challenging the automobile exception under article I, section 8.
The district court granted relief, reasoning the automobile exception’s viability under the Iowa Constitution was seriously in doubt and a suppression motion would have succeeded; the State appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for not filing a suppression motion challenging the automobile exception under the Iowa Constitution	Ortiz: counsel breached an essential duty by not raising a meritorious state-constitutional challenge to the automobile exception; prejudice follows because suppression would have prevented conviction	State/appeal: counsel made a reasonable strategic decision to avoid federal referral and greater exposure; no duty to attack long-standing precedent	Court: Counsel was not ineffective; declining to file the motion was a reasonable strategic choice, so no breach of duty and no relief granted

State v. Gaskins, 866 N.W.2d 1 (Iowa 2015) (warrantless-search presumptively unreasonable; discussion on state constitutional development)
State v. Allensworth, 748 N.W.2d 789 (Iowa 2008) (automobile-exception origins and reduced expectation of privacy rationale)
Carroll v. United States, 267 U.S. 132 (U.S. 1925) (original formulation of the automobile exception)
California v. Carney, 471 U.S. 386 (U.S. 1985) (reduced expectation of privacy in vehicles)
State v. Olsen, 293 N.W.2d 216 (Iowa 1980) (Iowa Supreme Court adoption of the automobile exception under the Iowa Constitution)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part ineffective-assistance-of-counsel test)
Kimmelman v. Morrison, 477 U.S. 365 (U.S. 1986) (failure to file suppression motion is not per se ineffective; strategic reasons may justify omission)