State of Iowa v. Brice Turner, 16-1241

Shortly after midnight on Aug. 30, 2015, Sgt. Kiel Stevenson observed Brice Turner drive a Toyota into a closed park, leave the paved area, and return; taillights were not functioning.
Sgt. Stevenson activated lights to stop the vehicle; Turner drove past the patrol car, avoided eye contact, exited the park, went across a lawn and into a pub parking lot before stopping.
Officers ordered Turner to remain in the vehicle; he exited, repeatedly moved contrary to commands, smelled of alcohol, had watery/red eyes, and showed unsteady gait and slurred speech.
At the station Turner refused field sobriety testing and a preliminary breath test; officers noted HGN indicators and invoked implied consent for a breath sample (which he refused).
Turner was charged with eluding and OWI (acquitted on separate controlled-substance counts), moved to suppress evidence and later waived a jury; the bench convicted him of eluding and OWI.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Vagueness of eluding statute	Statute is valid and was applied correctly	Turner: statute is unconstitutionally vague as to who decides when to stop	Not preserved; court declined review (claim not raised below)
Reasonable suspicion/probable cause to investigate OWI	Officers had sufficient facts (odor, appearance, conduct, passenger statement) to investigate and detain	Turner: his post-stop actions did not give officers reasonable suspicion of intoxication	Court: totality of circumstances supported continued detention and OWI investigation
Miranda/due process (failure to warn at scene)	Statements admissible; no custodial interrogation at scene requiring Miranda	Turner: failure to advise Miranda violated due process; evidence should be suppressed	Waived for review (not timely objected); court found no custodial interrogation at scene
Sufficiency of evidence — Eluding & OWI	Evidence (failure to stop after visual/audible signal, driving behavior, odor, HGN, unsteady gait, slurred speech, credibility of witness officers) proves both offenses beyond a reasonable doubt	Turner: acted out of fear and to reach a safer, well-lit place; movements/communications could be explained by noise/confusion; only drank modestly	Court affirmed: substantial evidence supports willful eluding and OWI; trier of fact rejected Turner’s credibility and accepted officer observations

State v. Neiderbach, 837 N.W.2d 180 (Iowa 2013) (standard of review for constitutional claims: de novo)
State v. McIver, 858 N.W.2d 699 (Iowa 2015) (reasonable-suspicion inquiry uses totality of circumstances)
State v. Bower, 725 N.W.2d 435 (Iowa 2006) (definition of "willful" for statutes criminalizing morally questionable conduct)
State v. Azneer, 526 N.W.2d 298 (Iowa 1995) (distinction between malum in se and malum prohibitum for "willful" definitions)
State v. Truesdell, 679 N.W.2d 611 (Iowa 2004) (definition of "under the influence" and evidentiary sufficiency for OWI)