State of Iowa v. Johnny Lee McFadden, Jr.
16-1184
| Iowa Ct. App. | Sep 27, 2017Background
- Des Moines police in a "summer enforcement team" stopped McFadden's car after observing a partially illegible (grime-covered) license plate.
- Officers contacted McFadden, confirmed license/registration and ran record checks; checks cleared and McFadden had a valid license.
- An officer noticed a backpack wedged between the front seats with two adult men in the car and asked about its contents; McFadden initially denied consent to search.
- After an officer joked, McFadden stated the backpack contained six pounds of marijuana. Officers then removed, handcuffed, and searched McFadden and the backpack, finding six compressed bricks of marijuana.
- McFadden was charged with possession with intent to deliver, moved to suppress the backpack evidence, the district court denied suppression, he stipulated to a bench trial, was convicted, and appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was supported by probable cause | Stop was lawful because the dirty/illegible plate violated Iowa Code §321.38, giving probable cause | Stop was pretextual or unsupported; stop merits review | Held: Stop was lawful — dirty/obstructed plate provided probable cause (traffic violation) |
| Whether officers unconstitutionally prolonged the stop to seek consent/search the backpack | Officers could conduct unrelated inquiries during stop; asking about backpack was permissible and produced admission | Once traffic tasks were complete, further questioning/search required reasonable suspicion; officers prolonged detention and lacked reasonable suspicion | Held: Stop was unlawfully prolonged when officer asked to search the backpack after traffic-related tasks concluded; no reasonable suspicion justified extension; evidence suppressed |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (traffic-stop reasonable where officer has probable cause to believe a traffic violation occurred)
- Rodriguez v. United States, 135 S. Ct. 1609 (2015) (a stop may not be prolonged beyond the time reasonably required to handle the traffic violation absent reasonable suspicion)
- Illinois v. Caballes, 543 U.S. 405 (dog sniff during lawful traffic stop not violative if it does not prolong the stop)
- Florida v. Royer, 460 U.S. 491 (seizure must be limited in scope and duration to the justification for the stop)
- Terry v. Ohio, 392 U.S. 1 (investigative stop standard: requires specific and articulable facts)
- Illinois v. Wardlow, 528 U.S. 119 (presence in high-crime area and nervousness evaluated in reasonable-suspicion analysis but insufficient alone)
- State v. Pardee, 872 N.W.2d 384 (Iowa) (applying Rodriguez principles to traffic stops)
- State v. Tyler, 830 N.W.2d 288 (Iowa) (Fourth Amendment protections against unreasonable searches and seizures)
- State v. Storm, 898 N.W.2d 140 (Iowa) (standard of review for suppression rulings)
- State v. Pals, 805 N.W.2d 767 (Iowa) (probable cause for traffic stop under Whren)
- State v. Tague, 676 N.W.2d 197 (Iowa) (reasonable suspicion requires specific, articulable facts)
