State of Iowa v. Jayel Antrone Coleman
2017 Iowa Sup. LEXIS 11
| Iowa | 2017Background
- Officer Morris stopped a car after a license-plate check showed the registered owner, Arvis Quinn, had a suspended license; the officer could not initially see the driver’s gender.
- Upon approach, Morris saw the driver was male (Jayel Coleman), so the original basis for the stop (owner Quinn driving while suspended) was dispelled.
- Morris nevertheless asked Coleman for license, registration, and proof of insurance; Coleman produced an Iowa ID, which revealed he was driving while barred.
- Coleman was charged with driving while barred, moved to suppress, and lost in district court; the court of appeals affirmed.
- The Iowa Supreme Court granted further review to decide whether under article I, §8 of the Iowa Constitution a stop must end once reasonable suspicion that justified it is resolved.
- The Court (majority) held the stop must end when the reasonable suspicion is gone and reversed; a three-justice dissent would have upheld the license check under federal Fourth Amendment principles.
Issues
| Issue | Plaintiff's Argument (Coleman) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether an officer may continue a traffic stop to request license/registration/insurance after the original reasonable suspicion is dispelled | Once the reason for the stop ended (driver not the registered owner), the State could not lawfully prolong the seizure to request documents | Officer may carry out ordinary inquiries (license/registration/insurance) incident to a lawful stop even after the initial concern is resolved | Held for Coleman: under article I, §8 (Iowa Constitution), the stop must end when reasonable suspicion is no longer present; further detention requires new reasonable suspicion |
| Whether Jackson controls Iowa law permitting post-exoneration license checks | Jackson permitted such checks and therefore the detention was lawful | State relied on Jackson and federal cases allowing license checks as routine inquiries | Jackson is overruled to the extent inconsistent with today’s decision |
| Whether federal precedents (Rodriguez/Caballes/Terry/Prouse) require a different approach | State urged coextensive federal analysis permitting ordinary inquiries during a stop | Coleman argued state constitution provides broader protection that forbids prolongation absent suspicion | Court applies independent Iowa constitutional analysis and aligns with majority of state and federal appellate decisions restricting post-exoneration extensions |
| Whether officer safety justifies continuing the stop absent reasonable suspicion | Not argued as a factual basis here; no concrete officer-safety facts in record | State argued safety and investigatory needs permit identification checks as ordinary and minimal intrusion | Court: generalized officer-safety claim insufficient; allowing free departure after resolution does not increase risk and officer-safety concerns must be supported by particularized suspicion |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (Terry-stop framework for brief investigative detentions)
- Delaware v. Prouse, 440 U.S. 648 (1979) (random stops for license/registration checks violate Fourth Amendment)
- Florida v. Royer, 460 U.S. 491 (1983) (investigatory stops must be tailored to and last no longer than necessary to effectuate the stop’s purpose)
- Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during lawful stop not a Fourth Amendment search, but seizure cannot be prolonged beyond mission)
- Rodriguez v. United States, 575 U.S. (2015) (traffic-stop may not be prolonged beyond mission for a dog sniff absent independent reasonable suspicion; ordinary inquiries include license/registration/warrants)
- United States v. McSwain, 29 F.3d 558 (10th Cir. 1994) (once purpose of stop is dispelled, further detention to ask questions and request documents exceeded scope)
- State v. Jackson, 315 N.W.2d 766 (Iowa 1982) (earlier Iowa decision permitting license request after stop; overruled to extent inconsistent)
- In re Property Seized from Pardee, 872 N.W.2d 384 (Iowa 2015) (applying Rodriguez and suppressing evidence from a prolonged stop)