State of Iowa v. Michelle Katherine Stockman, 20-1360

In early 2019 Stockman told Cresco police Christopher Weigert (her ex/partner) had firearms and supplied meth; a confidential informant reported Weigert solicited a hit on Stockman. FBI took over and sought a federal warrant.
On March 18, 2019 a U.S. magistrate issued a federal search warrant for Weigert’s residence and “any person, vehicles, and outbuildings located at [address],” plus specified items related to drugs/weapons.
On execution (March 20) federal agents, assisted by Cresco police, found Stockman asleep in the master bedroom; officers searched a purse found there and a vehicle and recovered paraphernalia and methamphetamine; Stockman was arrested and meth was later found in her boot during jail booking.
Stockman moved to suppress evidence, arguing she was not named in the warrant and had a reasonable expectation of privacy in her purse and vehicle; she also argued the booking search was fruit of the poisonous tree.
The district court denied suppression, finding Stockman’s statements to police (included in the warrant application) negated her expectation of privacy; on appeal the Court of Appeals applied federal Fourth Amendment law (following Ramirez) and relied on United States v. Simmermaker.
The court held the federal warrant, as applied, authorized the search of Stockman’s purse (and thus her arrest and the subsequent jail booking search), and affirmed the denial of the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a federal warrant authorizing search of “any person/vehicle” at the residence permits searching a visitor’s purse not named in the warrant	Warrant language and federal execution control; federal warrant valid and state courts should not invalidate it	Warrant did not name Stockman; visitor retains privacy in purse and vehicle absent specific authorization	Applying federal law and Simmermaker, the court held the affidavit gave particularized suspicion linking Stockman to the illicit activity, so the warrant authorized searching her purse
Whether Stockman had a legitimate expectation of privacy in her purse/vehicle	State: either no reasonable expectation or it was overcome by probable cause in affidavit	Stockman: had a Fourth Amendment expectation of privacy; Brown under Iowa law protects unnamed visitors’ purses	Court: Stockman had a Fourth Amendment expectation, but the affidavit’s information supplied the probable-cause nexus that overcame it under federal law; Ramirez dictates federal standard controls here
Whether meth found during jail booking is admissible or fruit of the poisonous tree	Arrest lawful based on lawful purse search; booking search routine and admissible	Arrest tainted by unlawful searches, so booking search evidence must be suppressed	Because purse search was lawful, arrest was lawful and the booking search was not tainted; evidence admissible

State v. Ramirez, 895 N.W.2d 884 (Iowa 2017) (state court applies the law of the jurisdiction that conducted a bona fide federal search and will not reexamine a valid federal search under differing state standards)
United States v. Simmermaker, 998 F.3d 1008 (8th Cir. 2021) (visitor connected to house’s drug activity can be subject to warrant-based search of personal containers when affidavit gives particularized suspicion)
State v. Brown, 905 N.W.2d 846 (Iowa 2018) (under Iowa Constitution, unnamed visitors generally retain privacy in purses during residence searches)
State v. Davis, 679 N.W.2d 651 (Iowa 2004) (evidence from out-of-state-authorized searches may be admissible in Iowa where the foreign jurisdiction’s law would have allowed the search)