State of Iowa v. Bounmy Bounmy, 15-2225

Early morning stop of a tan Honda Accord after Deputy Struve observed it travel 4 mph over the posted limit; vehicle had been reported by another county as coming from a "known drug house."
Driver (limited English) and two passengers (front-seat male, back-seat female Bounmy) were in the car; deputy issued a speed warning and ran license/registration/warrants.
Deputy questioned driver and passengers about their itinerary; inconsistencies and nervousness observed; deputy then asked driver to "stick around" for additional questions and to allow a K-9 walk-around.
Deputy escorted Bounmy toward a patrol car; while being escorted she allegedly dropped a baggie of methamphetamine, later admitted as hers; further meth found on her person at the jail.
District court denied suppression, finding the stop valid, consent voluntary, and drugs discovered in plain view; Court of Appeals reviewed de novo and applied Rodriguez and In re Pardee.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Bounmy)	Held
1. Probable cause for initial stop	Speeding (4 mph over) provided probable cause to stop	Stop was a single deceleration event and insufficient	Held for State: observed speeding gave probable cause to stop
2. Pretextual stop	Objectively valid traffic basis controls; pretext allowed under federal test	Stop was pretextual because deputies followed for drug suspicion	Held for State: bound by precedent that applies objective Whren test
3. Prolongation of the stop / dog sniff	Deputies had reasonable suspicion from drug-house tip, inconsistent stories, nervousness	Questioning unrelated to traffic mission impermissibly prolonged stop; no reasonable suspicion to continue	Held for Bounmy: deputy unlawfully prolonged stop; no reasonable suspicion to detain further for dog sniff
4. Validity of driver’s consent to further questioning/escort	Driver consented to additional questioning; consent justified continued detention	Consent was not voluntary (language/cultural barriers) and was tainted by prior illegal detention	Held for Bounmy: any consent was tainted by the prior unlawful prolongation and cannot justify detention

In re Pardee, 872 N.W.2d 384 (Iowa 2015) (roadside dog sniff impermissible where stop was prolonged and reasonable suspicion arose only after unlawful extension)
Rodriguez v. United States, 135 S. Ct. 1609 (2015) (traffic-stop mission defines permissible duration; dog sniff unrelated to mission cannot extend detention absent independent reasonable suspicion)
Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (consent to search must be voluntary under totality of circumstances)
Whren v. United States, 517 U.S. 806 (1996) (objective test allows pretextual traffic stops under Fourth Amendment)
State v. Kreps, 650 N.W.2d 636 (Iowa 2002) (Iowa follows objective approach in assessing traffic-stop validity)
State v. Tague, 676 N.W.2d 197 (Iowa 2004) (single brief lane departure may not suffice for a traffic stop under specific statute)
State v. Lane, 726 N.W.2d 371 (Iowa 2007) (consent admissible only if voluntary and not exploitation of prior illegality)