State of Iowa v. Tommy Tyler, Jr.
2013 Iowa Sup. LEXIS 44
| Iowa | 2013Background
- Officer observed Tommy Tyler’s vehicle in a parking lot and then on Merle Hay Road; suspected a license plate frame blocked the plate under Iowa Code section 321.37(3).
- Officer stopped Tyler for what he believed to be an obscured license plate; the stop was videotaped and led to an OWI charge following a Breathalyzer reading of .147.
- Evidence at suppression hearing showed the rear and front plates were readable and unobscured in the video; officer had previously stopped a day or two earlier over similar concerns.
- Tyler moved to suppress; district court denied; the court of appeals affirmed; this court granted review to address Fourth Amendment and Iowa Constitution issues.
- The court conducted de novo review of whether the stop was supported by probable cause or reasonable suspicion, focusing on whether officer’s law and facts supported the stop and whether any mistaking by officer was reasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause to stop based on 321.37(3) | Officer observed obscured plate frames; fact pattern supports stop | Officer’s belief was mistaken in law; no valid basis | No probable cause; stop invalid |
| Mistake of law vs. mistake of fact | Mistake of law invalidates stop; plate was readable | Mistake of fact could justify stop if objectively reasonable | Mistake of law invalidates; no alternate justification shown |
| Reasonable suspicion to justify stop | Ambiguity about whether crime was afoot justified stop | Officer sought to investigate ongoing offense | No reasonable suspicion; stop unconstitutional |
| Use of alternative grounds under Heminover | State may justify stop by other statutes | No alternative grounds supported the stop | No alternative justification shown; suppression required |
Key Cases Cited
- Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (traffic stops are seizures under the Fourth Amendment)
- Heminover, 619 N.W.2d 353 (Iowa 2000) (recognizes stop authority in traffic context)
- Tague, 676 N.W.2d 197 (Iowa 2004) (probable cause for traffic stop where violation witnessed)
- Lloyd, 701 N.W.2d 678 (Iowa 2005) (mistake of fact can justify a stop; not a mistake of law)
- Louwrens, 792 N.W.2d 649 (Iowa 2010) (burden of proof for probable cause; suppression if not met)
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (probable cause evaluated objectively by reasonable officer)
- Pals, 805 N.W.2d 767 (Iowa 2011) (discussion of reasonable suspicion vs. per se prohibition; state has burden)
- Reisetter, 747 N.W.2d 792 (Iowa Ct.App.2008) (readability/illumination issues; distance considerations)
- Kinkead, 570 N.W.2d 97 (Iowa 1997) ( Fourth Amendment protections in traffic stops)