State of Iowa v. Craig E. Harrison
2014 Iowa Sup. LEXIS 47
| Iowa | 2014Background
- Police stopped Harrison's Jeep because a license plate frame obscured the county name; the officers also relied on an informant tip and evasive driving, but Harrison was not charged with a plate violation.
- Harrison was charged with possession with intent to deliver crack cocaine, a drug tax stamp violation, and driving while suspended; no license plate charge was brought at charging.
- Two district court judges issued conflicting suppression rulings: one deemed the plate issue pretextual but permitted the stop based on other facts; another upheld the stop based on the plate frame.
- The Court of Appeals upheld the stop based on reasonable suspicion of drug dealing and affirmed the plea-agreement issue; the Supreme Court granted review to address whether the plate frame violated § 321.37(3).
- The Iowa Supreme Court held that a license plate frame covering the county name violates § 321.37(3) and provides a valid basis for a traffic stop, vacated the appellate ruling on the reasonable-suspicion issue, and affirmed the plea-agreement ruling and the district court judgment and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether covering the county name violates § 321.37(3). | Harrison: frame coverage does not violate § 321.37(3). | State: frame obscuring county name violates § 321.37(3). | Yes; frame violates § 321.37(3) and justifies the stop. |
| Whether the stop was independently justified by reasonable suspicion of drug dealing. | Harrison argued no independent basis; stop based on plate alone. | State argued informant tip and corroboration supported reasonable suspicion. | Not decided on the merits; the court vacated the appellate ruling on this issue. |
| Validity of withdrawal from a plea agreement. | Harrison challenged the State's withdrawal. | State contends withdrawal was proper. | Affirmed the court of appeals on the plea agreement issue. |
Key Cases Cited
- State v. Romer, 832 N.W.2d 169 (Iowa 2013) (statutory interpretation and harmonizing related provisions)
- State v. Walker, 804 N.W.2d 284 (Iowa 2011) (textual meaning and purpose of statutes governing vehicle identification)
- State v. Byers, 456 N.W.2d 917 (Iowa 1990) (words presumed ordinary usage; interpret interrelated statutes)
- State v. Snyder, 684 N.W.2d 613 (Iowa 2001) (harmonizing interrelated provisions to define motor vehicle)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (pretextual stops allowed under Fourth Amendment)