State of Iowa v. Steven Edward Struve, 956 N.W.2d 90

At ~9:00 p.m., Clinton police observed Steven Struve driving while holding a lit cell phone up near his face and manipulating the screen with his thumb for about ten seconds; dashcam recorded the encounter.
Officers followed alongside, concluded he might be violating the revised Iowa texting-while-driving statute (Iowa Code §321.276) and initiated a traffic stop to investigate.
During the stop officers saw a suspected meth pipe in plain view, searched the vehicle, recovered ~20+ grams of suspected methamphetamine, and arrested Struve.
Struve moved to suppress the evidence, arguing the initial stop lacked reasonable suspicion that he was committing a traffic violation; the district court denied the motion.
On appeal to the Iowa Supreme Court the sole issue was whether the officers had the specific and articulable facts necessary to justify a brief investigatory stop under the Fourth Amendment and article I, §8.
The Iowa Supreme Court affirmed, holding the observed conduct (phone held before face and actively manipulated for ~10 seconds) gave officers reasonable suspicion to stop and investigate under §321.276.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Struve)	Held
Whether officers had reasonable suspicion to stop a driver for suspected violation of Iowa Code §321.276 based on seeing a lit phone held before the driver’s face and the driver manipulating the screen for ~10 seconds	The observations—bright screen near face and thumb manipulating it for a sustained period—are specific, articulable facts that, given commonsense and empirical evidence about texting while driving and the statute’s expanded prohibitions, create reasonable suspicion to stop and investigate	Mere possession/brief use of a phone and screen manipulation is consistent with numerous lawful uses allowed by §321.276; those observations are at most a hunch and do not supply objective, particularized suspicion to support a stop	The court held that these observations, viewed in context of the statute’s expanded prohibitions and commonsense inferences, provided reasonable suspicion to justify a brief investigatory stop; suppression denial affirmed

Kansas v. Glover, 140 S. Ct. 1183 (recognizing commonsense inferences can supply reasonable suspicion for a stop)
State v. Vance, 790 N.W.2d 775 (Iowa 2010) (permitting reliance on commonsense inference that registered owner is likely the driver)
State v. Kreps, 650 N.W.2d 636 (Iowa 2002) (investigatory-stop reasonable-suspicion standard for traffic stops)
United States v. Paniagua-Garcia, 813 F.3d 1013 (7th Cir. 2016) (observing phone use may be indistinguishable from lawful uses; no reasonable suspicion under narrower texting statute)
State v. Morsette, 924 N.W.2d 434 (N.D. 2019) (no reasonable suspicion where officer saw ~2 seconds of touchscreen manipulation at a light)
State v. Rabanales-Ramos, 359 P.3d 250 (Or. Ct. App. 2015) (no probable cause where trooper observed light on device but could not identify prohibited use)
State v. Nguyen Ngoc Pham, 433 P.3d 745 (Or. Ct. App. 2018) (probable cause where officer observed driver pushing screen and immediately lowering device on seeing patrol car)