State of Iowa v. Cody Tyler Smith, 919 N.W.2d 1

At ~4:30 a.m., deputies responded to a single-vehicle accident: a car was in a roadside ditch and a passerby had seen a possible driver walking away; no injuries were reported.
Deputies found a Minnesota license belonging to Cody Smith on the ditch vehicle’s front seat; the vehicle was unlocked and showed no signs of injury.
A van later drove by, briefly stopped in a nearby driveway, then left; its plate was registered to a different Smith at the same Osceola address as the ditch vehicle’s registrant.
Deputy Smith followed and stopped the van, stating he was conducting a welfare check and suspected the van might contain the ditch driver or persons looking for him.
Cody was a front-seat passenger, wearing one boot, wet and muddy, displayed signs of intoxication, admitted driving the ditch vehicle, failed field tests, and registered a .184 BAC; he was convicted of OWI after a bench trial.
Cody moved to suppress the evidence from the stop; the district court and court of appeals upheld the stop as a community-caretaking function. The Iowa Supreme Court granted further review.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Smith)	Held
Was the traffic stop permissible under the community caretaking exception to the warrant/seizure requirement?	The stop was a bona fide community-caretaking welfare check: a vehicle was in a ditch at 4:30 a.m., registrations matched a nearby address, and the van may have contained or been seeking the driver.	The stop was investigatory (aimed at finding and investigating the ditch driver), not genuinely caretaking; deputies had no objective indication of an emergency involving the van occupants and less intrusive alternatives existed.	The Court held the stop was not justified by the community-caretaking doctrine under article I, § 8 of the Iowa Constitution; the seizure violated the constitution, so suppression was required and the conviction was reversed.

State v. Coffman, 914 N.W.2d 240 (Iowa 2018) (articulates three-step community-caretaking inquiry and requires objective and subjective proof under Iowa Constitution)
State v. Crawford, 659 N.W.2d 537 (Iowa 2003) (framework for community-caretaking exception)
State v. Storm, 898 N.W.2d 140 (Iowa 2017) (de novo review standard for suppression rulings)
State v. White, 887 N.W.2d 172 (Iowa 2016) (independent evaluation of totality of circumstances on suppression)
State v. Kurth, 813 N.W.2d 270 (Iowa 2012) (community-caretaking analysis depends on case-specific circumstances)