State of Iowa v. Brian Sean Moran, 15-2164

Late at night an off-duty Ogden police officer saw a Buick slowly drive onto his front yard and shine headlights into his bedroom window twice, behavior he viewed as possible harassment because of his status as an officer.
The off-duty officer called an on-duty Ogden officer, who located and stopped a vehicle matching the description in a small, low-traffic town shortly after the call.
The stopped vehicle was driven by Brian Moran; the on-duty officer asked for Moran’s license and learned Moran was driving while barred, leading to his arrest.
Moran was charged with driving while barred and convicted after a trial on the minutes of testimony; he was sentenced to two days in jail.
Moran moved to suppress evidence obtained after the traffic stop, arguing the stop was unlawful because the vehicle description was insufficient and the officers lacked reasonable suspicion.
The district court denied suppression; Moran appealed asserting the stop violated the Fourth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the traffic stop supported by reasonable suspicion?	The State: officer had reasonable suspicion based on report of possible harassment/threat and timely, matching description.	Moran: description was insufficient; conduct had an innocent explanation (lost/turning around).	Yes. Stop was justified under investigatory-stop standards; reasonable suspicion existed.
Could the off-duty officer’s report identify the vehicle for a lawful stop?	The State: make, timing, location, and low-traffic context sufficed to identify the vehicle.	Moran: description (make/color) was too vague to identify his car.	Court: description plus temporal and geographic proximity in small town was sufficient.
Must officers rule out innocent explanations before stopping?	The State: officers need only reasonable suspicion, not proof ruling out innocence.	Moran: argued his conduct was innocuous and officers should have considered that.	Court: officers need not rule out innocent explanations; permissible to briefly detain to resolve ambiguity.
Were evidentiary fruits of the stop admissible?	The State: seizure was lawful, so evidence (driving-while-barred) admissible.	Moran: evidence should be suppressed as fruit of unconstitutional stop.	Court: Denied suppression; evidence admissible and conviction affirmed.

Mapp v. Ohio, 367 U.S. 643 (1961) (Fourth Amendment exclusionary rule incorporated against states)
Whren v. United States, 517 U.S. 806 (1996) (traffic stops are seizures subject to Fourth Amendment reasonableness)
United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-the-circumstances, objective reasonable-suspicion test)
United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion may rest on less than probable cause)
State v. Kreps, 650 N.W.2d 636 (Iowa 2002) (purpose of investigatory stop is to resolve ambiguity; apply totality of circumstances)
State v. Tague, 676 N.W.2d 197 (Iowa 2004) (State bears burden to prove legality of stop by preponderance)
State v. Reynolds, 670 N.W.2d 405 (Iowa 2003) (proximity of vehicle to victim/home can support personal-contact harassment theory)