State of Iowa v. Joel Brooks
15-2073
| Iowa Ct. App. | May 17, 2017Background
- At ~2:00 a.m., Des Moines Police Officer Michael Dixson observed Joel Brooks merge from the University Avenue ramp onto southbound Keosauqua Way.
- Brooks’ vehicle entered the right southbound lane without signaling then, in one continuous motion, crossed the right lane into the left southbound lane directly in front of Officer Dixson’s marked squad car.
- Officer Dixson braked to avoid a collision, activated his emergency lights, and stopped Brooks; the encounter was captured on the officer’s dash-cam.
- Brooks was cited for improper lane change and later arrested and charged with possession of a controlled substance (second offense); OWI charge was dismissed per plea agreement.
- Brooks moved to suppress all evidence from the stop, arguing the officer lacked probable cause because Brooks had not violated Iowa Code §321.306(1) (failure to ascertain safe lane change).
- The district court denied suppression after observing testimony and video; Brooks appealed challenging only the denial of the suppression motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was supported by probable cause based on a lane-change violation | Officer Dixson/State: Brooks changed lanes without signaling and moved into the left lane in front of the squad car, forcing the officer to brake — a violation of local code/Iowa §321.306 | Brooks: Lane changes are common; slowing behind another vehicle does not prove he failed to ascertain safety — no probable cause for the stop | Affirmed: Court held the video and testimony showed Brooks failed to ascertain safety and did not signal; officer had probable cause to stop |
Key Cases Cited
- State v. Pals, 805 N.W.2d 767 (Iowa 2011) (standard of review for suppression rulings implicating constitutional rights)
- State v. Tague, 676 N.W.2d 197 (Iowa 2004) (any observed traffic-law violation, however minor, can supply probable cause for a stop)
- State v. Mitchell, 498 N.W.2d 691 (Iowa 1993) (probable cause for traffic stops may be based on observed traffic infractions)