State of Iowa v. Randall Lee Pals
2011 Iowa Sup. LEXIS 87
| Iowa | 2011Background
- Deputy stop Pals’ vehicle for dogs at large; observed Brittany and Lab and that Lab was not visible at first.
- Dog-ownership confirmed by a friend; deputy believed ongoing violation of Joice ordinance.
- Pals unable to produce proof of insurance; deputy gave verbal warning and asked Pals to accompany him to the patrol car.
- In the patrol car, deputy conducted a pat-down and then asked for consent to search; Pals consented and marijuana was found in the truck.
- District court denied suppression; Pals was convicted of possession of marijuana; court of appeals affirmed; Iowa Supreme Court granted review.
- Supreme Court vacated the court of appeals, reversed the district court, and remanded for further proceedings, holding the consent search involuntary under Iowa Constitution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the initial stop lawful under the Fourth Amendment and Iowa Constitution? | Pals argues stop was not supported by reasonable basis to detain for ongoing civil infraction. | State contends stop based on probable cause of ongoing civil offense and legitimate dog-at-large concerns. | Stop based on probable cause of an ongoing civil offense; lawful. |
| Was the consent to search voluntary under article I, section 8 of the Iowa Constitution? | Consent was coerced by the coercive environment of a traffic stop and detention. | Consent could be voluntary under Schneckloth and related totality-of-circumstances analysis. | Consent was not voluntary; taint not attenuated; suppression warranted. |
| Did Wubben impermissibly expand the scope of the investigation by requesting a search unrelated to the stop? | The search request was beyond the purposes of the stop and lacked reasonable suspicion. | Asserting a permissive approach to ask for consent without requiring additional suspicion. | Issue preserved/assessed but the majority declined to address due to preservation concerns; not central to the holding below. |
Key Cases Cited
- Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. 1973) (voluntariness of consent based on totality of circumstances)
- Robinette, 519 U.S. 33 (U.S. 1996) (traffic-stop consent and being told you are free to go; voluntary consent without per se rule)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (probable cause to stop a vehicle for a traffic violation; objective standard)
- Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (traffic stops are more like Terry stops; scope of seizures)
- United States v. Brignoni-Ponce, 422 U.S. 873 (U.S. 1975) (reasonable suspicion required to stop vehicle; Terry framework)
- State v. Lane, 726 N.W.2d 371 (Iowa 2007) (totality-of-the-circumstances review for voluntariness of consent)
- State v. Reinders, 690 N.W.2d 78 (Iowa 2004) (Iowa independent approach to consent under Iowa Constitution; no coercion)