State of Iowa v. Adam Donnell Boyd, 17-0333

Defendant Adam Boyd was charged with possession of a controlled substance (first offense), a serious misdemeanor, and pled guilty.
Arrest arose after an officer approached Boyd on suspicion there was an outstanding warrant; Boyd attempted to flee and struggled with officers.
During the struggle an officer searched Boyd’s right coin pocket and found a small bag of cocaine.
Police confirmed the outstanding warrant after the search and arrested Boyd.
District court sentenced Boyd to 365 days (all but 11 days suspended), fine and surcharges, one year supervised probation, and mandatory driver’s license revocation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence was an abuse of discretion	Sentence justified by crime’s nature, public protection, criminal and substance-abuse history, propensity for future crimes, and plea agreement	Sentence excessive; record lacks support for several stated reasons	No abuse: minutes of testimony and incident report support the court’s reasons
Whether counsel was ineffective for not moving to suppress drugs found in Boyd’s pocket	No breach because drugs would have been inevitably discovered; suppression motion would fail	Counsel should have moved to suppress as the pocket search violated Terry v. Ohio	No ineffective assistance: inevitable discovery doctrine applies; no breach and no prejudice

State v. Hill, 878 N.W.2d 269 (Iowa 2016) (standard of appellate review for sentencing abuse of discretion)
State v. Putnam, 848 N.W.2d 1 (Iowa 2014) (clarifies when a sentencing rationale is an abuse of discretion)
State v. Christianson, 627 N.W.2d 910 (Iowa 2001) (describes the inevitable discovery doctrine in Fourth Amendment context)
State v. Bearse, 748 N.W.2d 211 (Iowa 2008) (discusses adequacy of record for ineffective-assistance claims)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part test for ineffective assistance of counsel)
State v. Harris, 891 N.W.2d 182 (Iowa 2017) (applies Strickland standard in Iowa)
State v. Seager, 571 N.W.2d 204 (Iowa 1997) (explains limits and rationale for exceptions to the exclusionary rule)
Segura v. United States, 468 U.S. 796 (U.S. 1984) (supports limiting exclusionary rule where prosecution not put in worse position)