State of Iowa v. Jeffrey John Myers, 924 N.W.2d 823

On March 12, 2016, Jeffrey Myers was stopped for allegedly nonilluminated taillights; officers observed signs of impairment and arrested him after field sobriety tests.
Myers consented to a urine test; the DCI lab’s initial immunoassay screen returned positive for amphetamines (589 ng/ml) and marijuana metabolites (62 ng/ml) and stated these results indicate the “possible presence” of controlled substances and that a confirmatory report would follow.
The minutes of testimony included only the initial DCI report; no confirmatory test results were ever produced or included in the record.
Myers was charged under Iowa Code § 321J.2(1)(a) (under the influence) and (1)(c) (any amount of a controlled substance as measured in blood or urine); the district court found him guilty under the (c) theory and imposed mandatory penalties.
On appeal the court of appeals affirmed; the Iowa Supreme Court granted further review limited to whether the minutes supplied sufficient evidence to support a conviction under § 321J.2(1)(c).
The Iowa Supreme Court reversed, holding the initial screening test alone—labeled only as indicating a “possible presence”—was insufficient to prove beyond a reasonable doubt that any amount of a controlled substance was present in Myers’s urine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an initial DCI urine screening test alone can satisfy proof beyond a reasonable doubt that a controlled substance was present under § 321J.2(1)(c)	The State: the initial screen exceeded administrative cutoff levels and thus established a detectable amount; combined with circumstantial evidence of impairment, it supports conviction.	Myers: the initial immunoassay only indicates a “possible presence”; without a confirmatory test identifying a specific drug, evidence is insufficient.	The Court held the initial screen alone—stated as showing only a “possible presence”—does not meet the beyond-a-reasonable-doubt standard; conviction reversed and charge dismissed.
Whether circumstantial evidence of impairment can substitute for a confirmatory test under § 321J.2(1)(c)	The State: observations of impairment can corroborate the test and eliminate reasonable doubt.	Myers: behavior and field tests do not validate chemical presence; other causes may explain impairment.	The Court held circumstantial impairment evidence cannot cure the uncertainty of an unconfirmed screening result for the (c) offense.

State v. Comried, 693 N.W.2d 773 (Iowa 2005) (describes two-stage drug testing—initial screen and more reliable confirmatory test)
In re Winship, 397 U.S. 358 (U.S. 1970) (establishes the reasonable-doubt standard in criminal cases)
State v. Pexa, 574 N.W.2d 344 (Iowa 1998) (failure to consider alternative theory does not constitute acquittal for double jeopardy purposes)
State v. Childs, 898 N.W.2d 177 (Iowa 2017) (reaffirms application of § 321J.2 despite debates over nonimpairing metabolites)