997 N.W.2d 416
Iowa2023Background:
- On Feb. 19, 2022, at about 5:30 p.m., Iowa State Patrol troopers observed Chase Griffin’s SUV from behind; the rear license plate was shrouded by a dark/tinted plastic cover that made the plate hard to read while following closely on a shadowed highway.
- Troopers pulled close, could not fully read the numerals/letters while traveling behind the SUV, and stopped Griffin on the exit ramp to issue a warning for the suspected license-plate-cover violation of Iowa Code §321.37.
- During the stop, officers detected the smell of alcohol and saw two small children in the vehicle; Griffin was later charged with OWI and two counts of child endangerment.
- Griffin moved to suppress evidence from the stop, arguing the plate cover did not violate Iowa law; the district court granted suppression.
- The State appealed to the Iowa Supreme Court, which reversed: the Court held the cover violated §321.37 (it prevented full view of the plate), so the stop was lawful and suppression was improper.
Issues:
| Issue | State (Appellant) Argument | Griffin (Appellee) Argument | Held |
|---|---|---|---|
| Whether the plate cover violated Iowa Code §321.37, justifying the stop | Cover prevented full view of letters/numerals, so it violated §321.37 and gave probable cause for a stop | Tint alone does not automatically violate §321.37; cover did not actually violate statute | Court: Violation of §321.37 — cover prevented full view; stop lawful |
| Whether State v. Tyler precludes finding a tinted cover unlawful | Tyler only rejects a categorical rule; §321.37 prohibits covers that prevent full view, which occurred here | Tyler means tinted covers cannot be found unlawful as a class | Court: Tyler does not bar enforcement; only forbids categorical treatment of all tinted covers |
| Whether an officer’s alleged mistake of law invalidates the stop | Even if officers misstated or incompletely described the law, objective facts supported the stop; State not limited to officer’s stated reasons | A mistake of law (if present) makes the stop unconstitutional under Tyler | Court: A mistake of law does not defeat an otherwise justified stop; objective facts control |
| Whether readability of the plate after stopping negates the earlier violation | Violation occurred while troopers were following closely and could not read the plate; later readability at close range does not erase the earlier violation | Because the plate was readable after stopping, there was no violation to justify approaching and investigating | Court: Violation was complete while following; later readability does not negate lawfulness of the stop or subsequent approach |
Key Cases Cited
- Berkemer v. McCarty, 468 U.S. 420 (summary that traffic stop is a seizure under the Fourth Amendment)
- Heien v. North Carolina, 574 U.S. 54 (reasonableness of mistakes of law under the Fourth Amendment)
- State v. Tyler, 830 N.W.2d 288 (Iowa 2013) (license-plate covers not categorically prohibited; statute prohibits covers that prevent full view)
- State v. Brown, 930 N.W.2d 840 (Iowa 2019) (probable cause standard for traffic stops)
- State v. Harrison, 846 N.W.2d 362 (Iowa 2014) (statutory interpretation principles)
- Doe v. State, 943 N.W.2d 608 (Iowa 2020) (focus on legislative text in interpretation)
- State v. Burns, 988 N.W.2d 352 (Iowa 2023) (discussion of exclusionary rule history)