State of Iowa v. Christopher Todd Tusler, 15-1724

On Nov. 21, 2014, Floyd County deputies stopped Christopher Tusler's van after observing only one headlight illuminated while conducting building checks on Old Highway Road.
Deputies smelled alcohol, observed bloodshot/watery eyes, administered field sobriety tests, and recorded a breath test result of .130 BAC.
Tusler produced an ID and admitted his driver’s license was suspended. He was charged with OWI, third or subsequent offense (Iowa Code §321J.2).
Tusler moved to suppress evidence, introducing photos taken minutes before the stop showing both headlights working and testifying the lights remained functional afterward.
The district court credited the officers’ testimony and denied suppression. Tusler was convicted following a minutes-of-testimony trial and sentenced to an indeterminate five-year term.
On appeal Tusler argued the stop was illegal because the State did not prove (1) he was on a public road and (2) his vehicle lacked required lighting; the court found those arguments not preserved and affirmed denial of suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of traffic stop based on headlight violation	State: deputies observed only one headlight lit, giving reasonable suspicion/probable cause to stop	Tusler: photos and testimony show both headlights were working at the time of the stop, so no violation occurred	Court: district court credibility findings credited deputies; suppression denial affirmed
Whether State proved stop occurred on a public road	State: contends issue was not argued below; stop occurred on public road	Tusler (on appeal): argues State failed to prove stop was on a public road so §321.384 lighting rules don’t apply	Court: issue not preserved; Tusler had admitted location in suppression motion (Old Highway Road and Highway 18), so public-road concession undermines claim
Preservation of alternate lighting argument	State: defendant failed to preserve claim about alternate lighting/operating under special lighting	Tusler: raised alternate lighting on appeal (citing §321.384)	Court: claim not raised/decided below and thus not preserved; decline to address on appeal
Standard of review for suppression denial	State: suppression denial reviewed de novo but with deference to district court credibility findings	Tusler: challenges suppression de novo	Court: applies de novo review, defers to factual credibility findings, affirms denial

State v. Lane, 726 N.W.2d 371 (Iowa 2007) (de novo review of suppression with deference to credibility findings)
State v. Turner, 630 N.W.2d 601 (Iowa 2001) (consider totality of circumstances on suppression review)
State v. McIver, 858 N.W.2d 699 (Iowa 2015) (traffic offense observed by officer establishes probable cause to stop)
State v. Harrison, 830 N.W.2d 362 (Iowa 2013) (same—observed traffic violation supplies authority to stop)
State v. Rains, 574 N.W.2d 904 (Iowa 1998) (issues not raised in district court are not preserved on appeal)
State v. Lawler, 571 N.W.2d 486 (Iowa 1997) (appellate review limited to issues raised and decided below)