State of Iowa v. Cortez Jermaine Bryant, 24-1100

In December 2023, Cortez Bryant was stopped by Dubuque police, fled on foot, and was later apprehended.
After detaining Bryant, police returned to his vehicle and observed an unsealed vodka bottle in plain view on the passenger seat.
Officers conducted a warrantless search of the passenger compartment based on the open container, locating Bryant’s backpack containing controlled substances and related paraphernalia.
Bryant was charged with multiple controlled substance offenses and driving while barred; he moved to suppress the evidence found in his backpack, challenging the search's legality.
The district court denied his motion, holding that the plain view of the open container gave probable cause for a vehicle search under the automobile exception.
Bryant entered a conditional guilty plea, reserving appeal rights, and was sentenced; on appeal, he renews his suppression arguments.

Issue	Plaintiff (Bryant)'s Argument	Defendant (State)'s Argument	Held
Whether officers had probable cause to search the backpack under the automobile exception.	No probable cause or exigency; Bryant was detained, so his backpack was not subject to the exception.	Open container in plain view gave probable cause to search all containers that could hold contraband.	Probable cause existed; search justified under automobile exception.
Whether the officers needed a warrant to search the backpack after detaining Bryant.	Warrant was required, as neither exigency nor mobility justified search of the closed bag after detention.	Vehicle and all containers within are subject to search with probable cause, regardless of custody.	No warrant required; automobile exception applies.
Preservation of error for appeal regarding the legal scope of the open container law.	Bryant shifts argument on appeal to statutory interpretation of “contraband” under open container law.	State argues error not preserved; appeal limited to suppression motion arguments.	New argument not preserved; court did not consider it.
Jurisdiction to hear appeal of suppression denial after conditional plea.	Conditional plea agreement expressly reserved the suppression issue for appeal.	State initially challenged jurisdiction, citing new arguments on appeal.	Jurisdiction is proper under recent precedent.

State v. Fogg, 936 N.W.2d 664 (Iowa 2019) (standard for review of suppression based on state/federal constitutional rights)
State v. Storm, 898 N.W.2d 140 (Iowa 2017) (automobile exception requires only probable cause and inherent mobility)
State v. Rincon, 970 N.W.2d 275 (Iowa 2022) (open container provides probable cause to search vehicle and any container that could conceal alcohol)
State v. Chawech, 15 N.W.3d 78 (Iowa 2024) (issues must be raised and decided below to be reviewed on appeal)
State v. McClain, 20 N.W.3d 488 (Iowa 2025) (conditional plea appeals are limited to preserved issues; error preservation rules still apply)