State of Iowa v. Robert A. Davis, 922 N.W.2d 326

Deputy Cardenas responded to a snowstorm motor-vehicle crash; he smelled alcohol on Robert Davis and observed impairment (bloodshot eyes, admission of drinking, 6/6 HGN clues).
Due to weather, Cardenas transported Davis to the jail sally port (garage) to complete field sobriety tests instead of roadside testing.
At the scene and while seated in the patrol car, Davis asked to speak with his wife before leaving; Cardenas denied the request and said he could call after testing.
Davis performed two field sobriety tests at the sally port, failed, was arrested, taken to the jail intake room, allowed to call his wife and attorney, then submitted to a breath test showing .128 BAC.
District court suppressed the field sobriety-test results (finding the sally port a “place of detention” under Iowa Code § 804.20) but admitted the chemical test; the court of appeals affirmed the conviction, holding § 804.20 rights had not yet attached during the testing at the sally port.
The Iowa Supreme Court granted further review and affirmed the court of appeals: the sally port was a location for testing, not a “place of detention,” so § 804.20 was not violated prior to chemical testing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 804.20 right to call attaches before or during field sobriety testing conducted at a sally port	Davis: he was "restrained of his liberty" when placed in squad car and taken to sally port, so § 804.20 required immediate opportunity to call his wife before testing	State: § 804.20 triggers only after arrest/arrival at a place of detention (jail intake or station); sally port used for field testing, not detention	Held: No § 804.20 violation. Sally port was a testing location, not a “place of detention”; right to call attached after arrest and arrival at intake room

State v. Krebs, 562 N.W.2d 423 (Iowa 1997) (field sobriety testing during investigatory stop does not trigger § 804.20 right to call)
State v. Moorehead, 699 N.W.2d 667 (Iowa 2005) (when investigatory stage ends and suspect is effectively in custody, § 804.20 applies upon arrival at place of detention)
State v. Lamoreux, 875 N.W.2d 172 (Iowa 2016) (standard of review and guidance on interpreting § 804.20)
State v. Hellstern, 856 N.W.2d 355 (Iowa 2014) (§ 804.20 provides limited right to counsel before implied-consent chemical testing)
Wardlow v. State, 2 P.3d 1238 (Alaska Ct. App. 2000) (analogous interpretation that statutory right to call typically does not attach until arrestee is brought to a police station or jail)