State of Iowa v. Bradley Davisson, 16-0868

On April 7, 2015, a Cadillac was stolen from a Des Moines vehicle dealer; it was recovered April 9 in Madrid with a plastic cup and straw inside.
Police suspected Bradley Davisson and sought a warrant for his DNA to compare to the cup/straw.
Officers averred Davisson was arrested in Des Moines on April 6 in a stolen Yukon taken from a Madrid parking lot; he was released April 7 (day the Cadillac was stolen) from a jail eight blocks from the Des Moines dealer.
Police further alleged Davisson was later arrested in a truck stolen April 7 from a Madrid lot across the street from where the Cadillac was recovered.
The magistrate issued the DNA search warrant; Davisson moved to suppress the DNA evidence claiming the warrant lacked probable cause.
The district court denied the motion; Davisson appealed, challenging the sufficiency of probable cause supporting the warrant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant contained probable cause to obtain Davisson's DNA to compare with cup/straw found in the recovered Cadillac	The facts (possession of two other stolen vehicles from the same Madrid location, proximity in time/place, release near dealer, drink in car) create nexus and support probable cause to obtain DNA	The affidavit only places Davisson near locations/times and does not directly link him to the Cadillac theft or to the cup/straw	Court affirmed: magistrate had a substantial basis to conclude probable cause existed to obtain Davisson's DNA

State v. Green, 540 N.W.2d 649 (Iowa 1995) (probable cause standard for search warrants and requirement of nexus between criminal activity, items to be seized, and place to be searched)