State of Iowa v. Stacy James Levell, 17-0012

Trooper Robert Smith, while driving on the interstate, noticed a vehicle slow and fall back behind his patrol car; he ran a license-plate check showing the vehicle registered to two women and an arrest-warrant alert for Stacy Levell.
The vehicle exited to a rest area; as it pulled into a parking stall, Smith followed, activated emergency lights, parked beside the driver’s side, exited, and approached the driver’s window.
The driver identified himself as Stacy Levell; Trooper Smith learned Levell’s license was revoked and that Levell was barred from driving.
Levell moved to suppress, arguing the contact was an unconstitutional seizure lacking reasonable suspicion; the district court denied the motion, and Levell was convicted of driving while barred and driving while license revoked.
On de novo review, the appellate majority held the officer’s activation of emergency lights and positioning of his patrol car converted the encounter into a seizure, but that the trooper lacked reasonable suspicion to justify the seizure.
The court reversed the convictions; Judge McDonald dissented, arguing the encounter was consensual and not a seizure under Fourth Amendment precedent.

Issue	Levell's Argument	State's Argument	Held
Whether Trooper Smith’s actions constituted a "seizure" under the Fourth Amendment	The activation of emergency lights, following the car into a rest area, parking beside the driver, exiting the patrol car, and approaching the window amounted to a show of authority converting the encounter into a seizure	The State argued the contact was consensual because the vehicle was already stopped, the trooper only approached and asked questions, and no coercive force or authoritative commands were used	Majority: It was a seizure (lights, positioning, and approach would make a reasonable person feel they were not free to leave); Dissent: not a seizure (consensual questioning)
Whether there was reasonable suspicion to justify the stop/seizure	Levell argued the officer lacked specific, articulable facts tying Levell to driving the vehicle at that time; plate registration alone and the warrant alert were insufficient	The State argued evasive driving behavior (slowing and pulling off) plus the warrant/info that Levell sometimes drove the vehicle provided reasonable suspicion	Held: No reasonable suspicion — facts observed (slowing, pulling into rest area, proximity to home, plate info) amounted to at most an unparticularized hunch; suppression should have been granted

State v. Pals, 805 N.W.2d 767 (Iowa 2011) (standard for investigatory stops of moving vehicles)
State v. Wilkes, 756 N.W.2d 838 (Iowa 2008) (use of emergency lights may invoke police authority and imply a command to stop)
State v. White, 887 N.W.2d 172 (Iowa 2016) (distinguishing coercive effect of emergency lights)
State v. Vance, 790 N.W.2d 775 (Iowa 2010) (reasonable to infer registered owner does most driving)
Terry v. Ohio, 392 U.S. 1 (1968) (defining seizure and scope of investigatory stops)
United States v. Mendenhall, 446 U.S. 544 (1980) (whether a reasonable person would feel free to leave determines seizure)
Florida v. Bostick, 501 U.S. 429 (1991) (consensual encounters vs. seizures)