State of Iowa v. Christopher George Storm
2017 Iowa Sup. LEXIS 81
| Iowa | 2017Background
- On April 19, 2015 Deputy Leonard stopped Christopher Storm for a seatbelt violation in Dallas County, Iowa; Leonard smelled marijuana, questioned Storm, then searched the pickup and found marijuana packaged for sale, a scale, drug paraphernalia, and nonprescribed pills. Storm was arrested and charged with possession with intent to deliver and related offenses.
- Storm moved to suppress, arguing the warrantless vehicle search violated article I, § 8 of the Iowa Constitution because modern technology permits officers to obtain warrants remotely from the scene of a stop.
- The district court held an evidentiary hearing; officers testified they lacked reliable equipment, training, or procedures to obtain electronic warrants at the roadside and estimated preparing and obtaining a warrant would take well over an hour. A defense witness estimated 15–45 minutes using boilerplate.
- The district court denied the suppression motion, finding the deputy lacked the ability to obtain an electronic warrant at the scene and applying the automobile exception to permit the search. Storm was convicted; the Iowa Supreme Court retained the appeal.
- The Iowa Supreme Court (majority) affirmed: on the record, remote warranting was not practically available at the stop; the court retained the automobile exception under article I, § 8, citing federal precedent, Iowa precedent, and the policy costs of replacing the bright-line rule with a case-by-case exigency test.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the automobile exception to the warrant requirement should be abandoned under article I, § 8 given modern remote-warrant technology | Storm: mobility no longer creates a per se exigency because officers can obtain electronic warrants from the roadside; therefore warrantless vehicle searches should require case-specific exigency or a warrant | State: remote warrants were not practically available in this case (lack of equipment, training, procedures); bright-line automobile exception remains necessary for predictable, safe policing | Held: Court retained the automobile exception for now; on this record remote warrants were not practicable and the exception remains valid under Iowa Constitution |
| Whether the search of Storm’s vehicle was unconstitutional because a warrant could have been obtained remotely | Storm: specific facts show a warrant should have been obtained; suppression required | State: deputy lacked means to obtain a warrant at scene; exigent circumstances (mobility, officer safety, risk of evidence removal) justified search | Held: search lawful under the automobile exception; suppression denied |
| Whether Iowa law (Iowa Code § 808.3) requires physical presence of applicant before magistrate for a warrant | Storm: statute does not preclude electronic submission/oaths; remote procedures satisfy requirements | State: § 808.3 contemplates in-person submission and oath; telephonic/e-warrant practice not broadly available then | Held: Majority did not need to resolve statutory question (automobile exception dispositive); concurring/dissenting opinions analyze and differ on statutory interpretation; legislature later clarified permissive electronic submission |
| Whether abandoning the automobile exception would improve civil liberties given prolonged roadside detentions and safety risks | Storm: increased protections from warrant requirement outweigh delays | State: replacing bright-line rule would produce inconsistent exigency rulings, longer roadside delays, increased safety hazards, and more coerced consent searches | Held: Court favored preserving bright-line automobile exception to avoid those harms; may revisit when remote warrants are practical statewide |
Key Cases Cited
- Carroll v. United States, 267 U.S. 132 (establishing automobile exception where warrant impracticable due to vehicle mobility)
- Chambers v. Maroney, 399 U.S. 42 (permitting warrantless automobile searches based on mobility rationale; treating seizure pending warrant and immediate search similarly)
- Maryland v. Dyson, 527 U.S. 465 (per curiam) (automobile exception does not require separate exigency beyond mobility)
- California v. Carney, 471 U.S. 386 (recognizing "ready mobility" and reduced privacy expectations in vehicles)
- State v. Olsen, 293 N.W.2d 216 (Iowa 1980) (adopting automobile exception under article I, § 8)
- State v. Allensworth, 748 N.W.2d 789 (Iowa 2008) (applying and discussing automobile exception under federal and state law)
- State v. Witt, 126 A.3d 850 (N.J. 2015) (New Jersey reinstated automobile exception after experience showed telephonic-warrant exigency test produced delays, safety risks, and increased coerced consent searches)