State of Iowa v. Ryan Joseph Hahn, 20-0202

Background:

IDHS protection worker emailed Scott County deputies reporting suspected marijuana and pill use at Ryan Hahn’s residence; a child said Hahn traveled to Colorado and had pills.
Deputies performed a warrantless trash pull from bags in cans accessible from an alley and found a marijuana-dispensary receipt and other identifying items.
Using the trash pull results plus background information, deputies obtained and executed a warrant for the residence and seized marijuana, pills, and paraphernalia.
Hahn moved to suppress evidence, arguing the trash seizure/search violated the Fourth Amendment and Iowa Constitution; the district court denied the motion under existing Greenwood/Henderson law.
The Iowa Supreme Court (majority) concluded Wright (filed same day) requires warrant for trespassory garbage seizures, conditionally affirmed Hahn’s convictions, and remanded for a suppression hearing excluding the trash-derived information; a three-justice dissent argued Hahn failed to preserve the constitutional claim.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether deputies violated Fourth Amendment/Iowa Const. by seizing/searching trash without a warrant	State relied on Greenwood/Henderson framework permitting warrantless garbage searches if trash left for collection and outside curtilage	Hahn argued seizure was a trespassory intrusion into protected effects and violated his reasonable expectation of privacy	Majority: Under Wright, warrantless trespassory seizure/search of garbage is unconstitutional; remand for suppression hearing excluding trash-derived evidence
Preservation of constitutional challenge	State: Hahn failed to preserve a new constitutional argument below (he only disputed factual location)	Hahn: He challenged constitutionality within Greenwood/Henderson framework; issue preserved for appeal	Majority: Hahn preserved the issue; dissent: he did not preserve it and would not reach merits
Remedy for evidence obtained via trash pull (use to support warrant)	State: evidence used to obtain warrant should stand under the district court ruling	Hahn: Trash-derived evidence must be excluded and warrant re-evaluated without it	Held: Court conditionally affirmed and remanded; district court must hold suppression hearing without considering trash-derived information before proceeding
Application of new rule retroactively to pending cases	State implicitly argued existing precedent controlled	Hahn: New rule (Wright) should apply to pending cases	Held: Court applied new rule to this pending case and directed remand consistent with precedent applying new rules to pending appeals

Key Cases Cited

California v. Greenwood, 486 U.S. 35 (1988) (Supreme Court held no reasonable expectation of privacy in garbage left for collection)
State v. Henderson, 435 N.W.2d 394 (Iowa Ct. App. 1988) (applied Greenwood in Iowa context regarding trash and curtilage)
State v. Veal, 930 N.W.2d 319 (Iowa 2019) (conditional affirmance and remand for further proceedings when new rule affects suppression)
State v. Lilly, 930 N.W.2d 293 (Iowa 2019) (same remedial approach when new precedent requires reevaluation)
Schmidt v. State, 909 N.W.2d 778 (Iowa 2018) (when a new standard is created, remand to district court for application is appropriate)
Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (issues must ordinarily be raised and decided below to be reviewed on appeal)
State v. Bynum, 937 N.W.2d 319 (Iowa 2020) (constitutional issues must be preserved by raising them before the district court)