State of Iowa v. Jesse Jon Harbach, 3 N.W.3d 209

Jesse Harbach was involved in a one-vehicle rollover accident in Iowa; police suspected impairment.
Deputy Knipper applied for and obtained two warrants to draw Harbach’s blood for testing; initial attempts were delayed due to Harbach’s medical condition.
The first DCI blood test after a three-hour delay showed methamphetamine but no alcohol; a local serum test closer in time to the accident showed an ethanol level allegedly corresponding to .042 BAC.
Harbach moved to suppress the blood evidence, alleging the warrant contained intentionally or recklessly false statements by Knipper regarding observable intoxication, specifically the smell of alcohol and observations of impairment.
The district court granted suppression, finding the bodycam video contradicted Knipper’s claims and that remaining facts in the affidavit did not establish probable cause.
The Iowa Court of Appeals reversed, finding only the statements about test refusals were intentionally or recklessly false; the Supreme Court affirmed the Court of Appeals, reversing suppression.

Issue	Harbach's Argument	State's Argument	Held
Veracity of warrant statements (Franks standard)	Knipper’s claims of smelling alcohol and signs of intoxication were false and intentionally/recklessly made	Harbach failed to show statements were intentionally/recklessly false; inconsistencies were mistaken or explainable	The Franks standard was not met for most claims; only test refusal statements excised
Sufficiency of remaining probable cause	Without false statements, warrant lacked probable cause (accident alone insufficient)	Remainder of affidavit (single-vehicle accident, officer’s observations) established probable cause	Remaining affidavit (excluding false refusals) established probable cause to issue warrant
Consideration of omissions or alternate explanations	Omission of Harbach’s medical state/methods misleadingly strengthened impairment inference	Omission of every detail not required; sufficient info given for magistrate’s assessment	No material and intentional omission found; affidavit adequately described accident/injuries
Weight of bodycam/after-the-fact evidence	Bodycam and DCI test proved statements intentionally false; courts should credit these	Only supporting affidavit before magistrate generally considered; bodycam/test results may explain but do not prove intent	Results/blood draw timing explained; bodycam insufficient to prove intentional/reckless falsity beyond one statement

Franks v. Delaware, 438 U.S. 154 (1978) (sets the standard for challenging the veracity of search warrant affidavits)
State v. Groff, 323 N.W.2d 204 (Iowa 1982) (Iowa adopts Franks standard; misstatements must be intentional or reckless)
State v. Green, 540 N.W.2d 649 (Iowa 1995) (Franks standard applies to material omissions as well as false statements)
State v. Baker, 925 N.W.2d 602 (Iowa 2019) (reviewing court gives deference to issuing judge for probable cause)
State v. Bracy, 971 N.W.2d 563 (Iowa 2022) (reinforces deference to issuing judge in probable cause review)
State v. Harris, 490 N.W.2d 561 (Iowa 1992) (odor of alcohol and bloodshot, watery eyes can support finding probable cause in OWI context)
State v. Harlan, 301 N.W.2d 717 (Iowa 1981) (similar to Harris; probable cause supported by physical signs of intoxication)