State of Iowa v. Clifford Lynn McNeal, 2015 Iowa Sup. LEXIS 70

In June–October 2011 police investigated burglaries of construction-site tool trailers and a residential burglary; suspects included John Wey and Mike Jones.
Officer Harris uncovered phone records linking Wey to contemporaneous communications about the residential burglary and contacts with David Downen, who admitted buying stolen tools from Wey and Jones.
Jones later confessed (under a cooperation agreement) that he and Wey sold large loads of stolen construction equipment to Clifford McNeal and identified two drop locations tied to McNeal and his wife; Jones said McNeal had moved the stolen property shortly before Jones’s arrest.
Police received an anonymous tip locating a bluish-green enclosed trailer with a ladder on Copperhead Road; officers corroborated the trailer’s location, appearance, license/VIN, and that it was registered to a company connected to McNeal.
A Wapello County judge issued a search warrant; officers found stolen construction equipment in the trailer. McNeal was tried and convicted of first‑degree theft; he appealed after the district court denied his suppression motion.
The Iowa Supreme Court granted further review of a court of appeals decision that had reversed the conviction for lack of probable cause.

Issue	Plaintiff's Argument (State)	Defendant's Argument (McNeal)	Held
Validity of search warrant / probable cause to search trailer	Warrant supported by totality: named informant (Jones), corroboration, anonymous tip corroborated, nexus between stolen tools and trailer	Anonymous tip lacked reliability; without it (and without certain statements) there was no nexus tying stolen tools to the trailer	Affirmed: issuing judge had a substantial basis for finding probable cause under totality of circumstances
Reliance on anonymous tip	Tip was significantly corroborated by police (location, appearance, registration) and thus could be considered	Tip was anonymous; credibility not sufficiently established and the judge improperly relied on it	Corroborated anonymous tip permissible; even removing tip, remaining affidavit supported probable cause
Consideration of defendant’s prior conviction in magistrate’s assessment	Prior conviction is a legitimate, limited factor in assessing credibility and probable cause	Prior conviction unfairly tainted magistrate’s probable‑cause decision	Prior conviction may be considered; its use here was permissible and not outcome‑determinative
Ineffective assistance of counsel claims	N/A (State urges claims be left for PCR)	Trial counsel erred in multiple respects (witnesses, valuation, objections, discovery)	Record inadequate to resolve on direct appeal; claims preserved for postconviction proceedings

State v. Johnson, 756 N.W.2d 682 (Iowa 2008) (standard for de novo review of constitutional questions)
State v. Gogg, 561 N.W.2d 360 (Iowa 1997) (review limited to whether issuing judge had substantial basis for probable cause)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality‑of‑circumstances approach to affidavit sufficiency; deference to magistrate)
Florida v. J.L., 529 U.S. 266 (U.S. 2000) (anonymous tip alone ordinarily insufficient without corroboration)
Alabama v. White, 496 U.S. 325 (U.S. 1990) (corroborated anonymous tip can supply probable cause)
State v. Kooima, 833 N.W.2d 202 (Iowa 2013) (anonymous‑tip framework and indicia of reliability analysis)
State v. Weir, 414 N.W.2d 327 (Iowa 1987) (probable‑cause test: connection of items to crime and to place to be searched)
State v. Niehaus, 452 N.W.2d 184 (Iowa 1990) (removing offensive material from affidavit and reviewing remainder)
State v. Groff, 323 N.W.2d 204 (Iowa 1982) (nexus may be inferred from crime type, nature of items, and likely places for concealment)
State v. Godbersen, 493 N.W.2d 852 (Iowa 1992) (informant reliability factors and reasonable inferences for finding evidence at residence)