State of Iowa v. Jason Randall Clark
16-1521
| Iowa Ct. App. | Aug 2, 2017Background
- Around 12:05 a.m., two Panora officers driving near an intersection heard a sustained squealing of tires coming from the intersection and observed a vehicle pass through.
- Officers activated lights and stopped the vehicle driven by Jason Clark.
- During the stop, officers observed signs of intoxication; Clark was charged with OUI (Iowa Code §321J.2) and careless driving (§321.277A(1)) for creating unnecessary tire squealing.
- Clark moved to suppress evidence, arguing the traffic stop was an unconstitutional seizure; the district court denied the motion, finding reasonable suspicion.
- After a stipulated trial on minutes of testimony Clark was convicted and appealed, arguing the stop required probable cause rather than reasonable suspicion.
- The Court of Appeals reviewed de novo and concluded the officers had probable cause to stop for careless driving, affirming the convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the traffic stop lawful? | Officers had probable cause/could lawfully investigate careless driving after hearing sustained tire squeal | Stop was unconstitutional; only reasonable suspicion (or none) justified stop, not probable cause | Stop justified by probable cause to believe careless driving occurred; suppression denied |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (vehicle stop is a seizure; officer-observed traffic violations supply probable cause)
- Mapp v. Ohio, 367 U.S. 643 (Fourth Amendment applies to states through Fourteenth Amendment)
- Rodriguez v. United States, 135 S. Ct. 1609 (Fourth Amendment reasonableness is the touchstone for seizures)
- State v. Pals, 805 N.W.2d 767 (Iowa courts review suppression rulings de novo)
- State v. Kreps, 650 N.W.2d 636 (Iowa Constitution text parallels Fourth Amendment analysis)
- State v. Bumpus, 459 N.W.2d 619 (definition of probable cause)
- State v. Tague, 676 N.W.2d 197 (officer observing any traffic law violation has probable cause to stop)
- State v. McIver, 858 N.W.2d 699 (reasonable suspicion standard for investigative stops)