State Of Iowa Vs. Joshua Daniel Fleming, 790 N.W.2d 560

Fleming was convicted of possession of marijuana after a search at 922 Wright Avenue uncovered drugs and cash, including a small amount in Fleming's bedroom.
A search warrant for Nearman’s residence was executed; Fleming rented a bedroom there for $375/month with exclusive possession.
Officers searched Fleming’s bedroom during the overall house search, though the warrant named Nearman and did not specify Fleming’s room.
Fleming moved to suppress the bedroom evidence, arguing lack of probable cause for that room and violation of Fourth Amendment and Iowa Constitution rights.
The district court held the warrant extended to the entire residence and Fleming had no privacy interest in his bedroom; the court of appeals affirmed. The supreme court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Fleming have a reasonable expectation of privacy in his rented bedroom?	Fleming had exclusive possession of the room.	The room was within Nearman’s home and the broader community-living rule may apply.	Yes; Fleming has a reasonable expectation of privacy in his bedroom.
Was a separate warrant required to search Fleming’s bedroom?	The warrant for the residence authorized a search of the whole property.	No additional warrant needed if within scope of the single-family residence warrant.	Yes; a separate warrant was required for Fleming’s bedroom.
Does the exclusionary rule apply to suppress the bedroom evidence under the Iowa Constitution?	Unlawful search violated state constitutional rights; suppression required.	If warrant was valid or good faith exception applies, no suppression.	Suppression required; the Iowa Constitution bars the bedroom search.
Is there a good-faith exception to the exclusionary rule under Iowa law?	The state cannot rely on a faulty warrant to avoid suppression.	Good faith could save evidence under some circumstances.	No; Iowa rejects a good-faith exception in this context.

State v. Legg, 633 N.W.2d 763 (Iowa 2001) (two-step privacy analysis)
State v. Breuer, 577 N.W.2d 41 (Iowa 1998) (privacy expectation and scope framework)
Maryland v. Garrison, 480 U.S. 79 (U.S. 1987) (multiple-unit buildings and privacy expectations)
Payton v. New York, 445 U.S. 573 (U.S. 1980) (home-entry privacy expectations)
Katz v. United States, 389 U.S. 347 (U.S. 1967) (reasonable expectation of privacy and public access concepts)
Chapman v. United States, 365 U.S. 610 (U.S. 1961) (renters’ privacy and multi-unit dwellings)