State of Iowa v. Leon Kooima
2013 Iowa Sup. LEXIS 78
| Iowa | 2013Background
- Anonymous 911 tip reported a carload of drunk Rock Valley merchants in a silver 2009 Chevy Suburban, license BC229, leaving Doon for Rock Valley.
- Officers followed the Suburban; no observed traffic or equipment violations prior to the stop.
- Stop occurred at approximately 11:38 p.m. based solely on the anonymous tip; officer smelled alcohol after contact.
- Kooima underwent field sobriety tests and was arrested for OWI; breath test at 1:15 a.m. showed BAC of .088.
- District court denied suppression; bench trial resulted in conviction; Court of Appeals affirmed; Iowa Supreme Court granted review.
- Supreme Court held the stop violated the Fourth Amendment; all evidence from the stop suppressed; case remanded for new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether anonymous tip supported reasonable suspicion for a stop | Kooima contends tip lacked reliability and personal observations | State argues tip provided sufficient indicia of reliability under totality of circumstances | Stop unconstitutional; suppression of evidence required |
| Whether Iowa Constitution provides greater protection than the Fourth Amendment | Kooima seeks Iowa constitutional analysis for heightened protection | State relies on federal framework; Iowa analysis unnecessary | Court resolves under Fourth Amendment; Iowa Constitution not addressed |
Key Cases Cited
- Alabama v. White, 496 U.S. 325 (1990) (reasonableness of anonymous tips depends on reliability and totality of circumstances)
- Florida v. J.L., 529 U.S. 266 (2000) (anonymous tip lacking indicia of reliability cannot justify stop)
- United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion via totality of circumstances)
- Wong Sun v. United States, 371 U.S. 471 (1963) (fruit of the poisonous tree doctrine reference)
- State v. Walshire, 634 N.W.2d 625 (Iowa 2001) (anonymous tip with eyewitness details supports stop)
- Harris v. Commonwealth, 668 S.E.2d 141 (Va. 2008) (tip reliability depends on details and immediacy of observation)
- State v. Lee, 938 P.2d 637 (Mont. 1997) (tip lacking personal observation invalid for stop)
- State v. Miller, 510 N.W.2d 638 (N.D. 1994) (anonymous tip details insufficient to show probable knowledge)