State of Iowa v. Fethe Feshaye Baraki, 981 N.W.2d 693

Sioux City officers stopped Fethe Baraki after observing signs of impairment; Baraki is a native Tigrinya speaker who spoke and understood some English but had limited proficiency.
Officer Scherle administered a preliminary breath test (PBT) that exceeded the legal limit; Baraki was arrested and transported for an evidentiary breath test (DataMaster).
At the station, Scherle contacted LanguageLine for a Tigrinya interpreter but was told none was available within the time window required by Iowa Code § 321J.6(2).
Scherle read the statutory implied‑consent advisory aloud in English, offered Baraki a phone to call anyone (Baraki tried briefly), attempted online translation, and obtained Baraki’s assent; the DataMaster later showed a .114 BAC.
The district court suppressed the DataMaster results, finding Baraki did not understand the advisory; the State sought discretionary review and the Iowa Supreme Court reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to secure a Tigrinya interpreter before giving the implied‑consent advisory requires suppression	Officer made reasonable efforts (called LanguageLine, used phone, tried online translation); statutory advisory not rendered invalid	Advisory must be delivered in a language the motorist understands so consequences are actually comprehended	Reversed: officer satisfied the Garcia "reasonable efforts" standard; suppression not required
Whether the statute requires subjective comprehension of the advisory (motorist must understand legal consequences)	Objective reasonable‑efforts standard suffices; not every motorist must fully appreciate legal ramification	Court should require the motorist actually understand consequences before testing	Rejected: court disfavors a subjective test; only reasonable methods under the circumstances required
Whether offering a phone and brief opportunity to consult met consultation/notification expectations	Giving phone and chance to call anyone was a sufficient and even more generous consultation opportunity than § 804.20	Brief phone access was inadequate to ensure meaningful comprehension	Held adequate under the circumstances; officer reasonably tried to secure interpreter/assistance

State v. Garcia, 756 N.W.2d 216 (Iowa 2008) (adopted a "reasonable efforts" standard for conveying implied‑consent warnings to limited English speakers)
State v. Overbay, 810 N.W.2d 871 (Iowa 2012) (totality of circumstances and voluntariness review for chemical test consent)
State v. Kilby, 961 N.W.2d 374 (Iowa 2021) (implied‑consent procedure is statutory, not constitutional, and breath testing can be upheld as search incident to arrest)
State v. Lukins, 846 N.W.2d 902 (Iowa 2014) (summarizes Garcia: officers need only use reasonable methods to convey warnings)
State v. Piddington, 623 N.W.2d 528 (Wis. 2001) (source of the reasonableness standard quoted in Garcia)
Yokoyama v. Comm'r of Pub. Safety, 356 N.W.2d 830 (Minn. Ct. App. 1984) (holding interpreter desirable but not required if it would unduly interfere with evidence gathering)
State v. Jensen, 216 N.W.2d 369 (Iowa 1974) (evidence inadmissible upon failure to comply with implied‑consent statutes)
State v. Senn, 882 N.W.2d 1 (Iowa 2016) (discusses consultation rights under § 804.20 in the implied‑consent context)