State of Iowa v. Shannon See, 16-0470

At 2:45 a.m., officers responded to a report of a vehicle parked at a gas pump for ~30 minutes; Shannon See was the driver, Trivino Clark the front passenger, and an infant was in the back seat.
After running IDs, officers learned Clark had an outstanding warrant; they arrested him, searched his person incident to arrest, and found a glass pipe with marijuana residue.
Officers smelled marijuana on Clark (not from the vehicle), then told See they needed to search her car; she initially refused but complied after being told she could be arrested.
While exiting the vehicle an officer saw an unmarked pill bottle in See's hoodie pocket; officers searched the car and found marijuana in See’s purse, placed her under arrest, and later found prescription pills and methamphetamine residue on her person.
See moved to suppress the seizure and searches as warrantless and unconstitutional; the district court denied suppression, she was convicted on two misdemeanor counts after trial on the minutes, and she appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had probable cause to search See's vehicle	The presence of a marijuana pipe on Clark, odor of marijuana from Clark, and discovery of marijuana in See's purse supplied probable cause to search the vehicle and See	No probable cause: odor and pipe were tied to Clark/person, not the vehicle; no drugs or paraphernalia in plain view; See showed no indicia of drug use	Reversed: no probable cause to search the vehicle; evidence from vehicle and subsequent search of See should have been suppressed

State v. Coleman, 890 N.W.2d 284 (Iowa 2017) (standard of review for suppression rulings)
State v. Gaskins, 866 N.W.2d 1 (Iowa 2015) (independent review of suppression record and federal standards)
State v. Watts, 801 N.W.2d 845 (Iowa 2011) (warrantless searches are per se unreasonable except for well-established exceptions)
State v. Lewis, 675 N.W.2d 516 (Iowa 2004) (enumerating exceptions to the warrant requirement)
State v. Edgington, 487 N.W.2d 675 (Iowa 1992) (probable cause for vehicle search defined by reasonably prudent person standard)
State v. Eubanks, 355 N.W.2d 57 (Iowa 1984) (odor of burned marijuana from vehicle interior can supply probable cause)
State v. Crawford, 659 N.W.2d 537 (Iowa 2003) (State bears burden to prove an exception to warrant requirement)
State v. Maddox, 670 N.W.2d 168 (Iowa 2003) (totality of circumstances governs probable cause inquiry)