State v. Coleman

Decision Date10 February 2017
Docket NumberNo. 15-0752,15-0752
Citation890 N.W.2d 284
Parties STATE of Iowa, Appellee, v. Jayel Antrone COLEMAN, Appellant.
CourtIowa Supreme Court

Micki M. Meier of Meier Law Firm, Davenport, for appellant.

Thomas J. Miller, Attorney General, and Darrel Mullins, Assistant Attorney General, Michael J. Walton, County Attorney, and Robert C. Bradfield and Steve Berger, Assistant County Attorneys, for appellee.

APPEL, Justice.

In this case, we consider whether a law enforcement officer, after making a valid traffic stop supported by reasonable suspicion that an offense may be being committed, must terminate the stop when the underlying reason for the stop is no longer present. For the reasons expressed below, we hold that under the search and seizure provision of article I, section 8 of the Iowa Constitution, the stop must end when reasonable suspicion is no longer present.

I. Factual and Procedural Background.

On the evening of August 18, 2014, Officer James Morris was parked along Highway 61 in Eldridge, Iowa, conducting random computer checks on the license plates of passing motorists to see if the vehicle was reported stolen or if there were outstanding warrants associated with the owner of the vehicle. His check of the license plate of a vehicle that passed him revealed that the female registered owner, Arvis Quinn, had a suspended driver's license.

Because it was dark, Morris could not determine when the vehicle passed him whether the driver was male or female. Morris pulled the vehicle registered to Quinn over to investigate the possibility that Quinn was driving the vehicle while her license was under suspension. As Morris approached the vehicle, it was clear to Morris that the driver was male, not female.

Morris did not terminate the stop upon determining that Quinn was not the driver of the vehicle. Instead, Morris proceeded to ask the driver of the vehicle, Jayel Coleman, for his license, registration, and proof of insurance. Coleman did not produce a registration but did produce "an Iowa ID." Coleman stated that he was driving a vehicle he had borrowed from his sister. At the time Morris made his requests, Morris no longer had reasonable suspicion that a traffic offense had been committed.

Based on Coleman's identification, Morris determined that Coleman was driving while barred in violation of Iowa Code sections 321.555(1) and 321.561 (2013). He was so charged. Coleman filed a pretrial motion to suppress with the district court. The district court denied the motion. After a bench trial, Coleman was convicted of the offense.

Coleman appealed. We transferred the case to the court of appeals. The court of appeals affirmed the conviction. Coleman sought further review, which we granted. For the reasons expressed below, we vacate the decision of the court of appeals and reverse the judgment of the district court.

II. Standard of Review.

We review the district court's denial of a motion to suppress on constitutional grounds de novo. State v. Tyler , 867 N.W.2d 136, 152 (Iowa 2015). In reviewing a search and seizure dispute under article I, section 8 of the Iowa Constitution, we construe the provision "in a broad and liberal spirit." State v. Height , 117 Iowa 650, 657, 661, 91 N.W. 935, 937–38 (1902) (construing fundamental guarantees, like the right against self-incrimination, broadly and liberally). We strongly favor the warrant requirement, subject only to "jealously and carefully drawn exceptions." State v. Strong , 493 N.W.2d 834, 836 (Iowa 1992) ; accord State v. Ochoa , 792 N.W.2d 260, 285 (Iowa 2010). In interpreting article I, section 8, we may look to federal caselaw, the caselaw of other states, the dissenting opinions of state and federal courts, and to secondary materials for their persuasive power. State v. Short , 851 N.W.2d 474, 481 (Iowa 2014).

III. Issue Preservation.

We must initially confront issue preservation. In the district court proceedings, Coleman did not identify either the Iowa or the Federal Constitution in support of his motion to suppress. Further, the district court, in its ruling, simply stated that the motion to suppress was denied.

On appeal, Coleman cites both article I, section 8 of the Iowa Constitution and the Fourth Amendment. Coleman essentially makes the same argument under both constitutional provisions—namely, that the seizure of Coleman could not be constitutionally extended once the underlying reason for the stop was resolved.

The State does not contest error preservation. In its briefing on appeal, the State recognizes that Coleman has made claims under article I, section 8 and the Fourth Amendment. Like Coleman, the State makes the same argument under both constitutional provisions. The State asserts that prolonging the stop to ask for a driver's license, registration, and proof of insurance is permissible.

We find the state constitutional issue is minimally preserved. We have held that when a defendant in the trial court only identifies the Fourth Amendment as the basis for a search and seizure claim, the state constitutional claim has not been preserved at the district court. State v. Prusha , 874 N.W.2d 627, 630 (Iowa 2016).1

Here, however, the defendant did not identify either constitution in the trial court although it was apparent that he was raising a search and seizure claim. This raises a different preservation question than that presented in Prusha. We have said that when a party brings a constitutional claim but fails to identify whether the party is proceeding under the Iowa or the Federal Constitution, claims under both the Iowa and the Federal Constitutions are preserved. State v. Harrington , 805 N.W.2d 391, 393 n.3 (Iowa 2011) ; King v. State , 797 N.W.2d 565, 571 (Iowa 2011). The State impliedly recognized our prior caselaw by declining to challenge issue preservation under the Iowa Constitution and addressing both claims. We adhere to the approach in Harrington and King .

On appeal, Coleman did not state the claim under the Iowa Constitution should be evaluated under a standard different than that employed by the United States Supreme Court in Fourth Amendment cases. Nonetheless, he makes only one argument on appeal, namely, that once reasonable suspicion for the original traffic stop was resolved, the State could not extend the stop by asking for Coleman's driver's license, registration, and insurance. It would elevate form over substance to declare that Coleman's argument actually cannot be considered under the Iowa Constitution because he did not specifically state that he was asking the court to depart from uncertain federal law. In any event, we reserve the right to apply principles established in the federal caselaw in a fashion different from prevailing federal law. See, e.g. , State v. Pals , 805 N.W.2d 767, 771–72 (Iowa 2011) ; State v. Bruegger , 773 N.W.2d 862, 883 (Iowa 2009). Under these circumstances, the argument Coleman specifically made and specifically asks us to resolve is preserved under the Iowa Constitution.

IV. Discussion.

A. Introduction. The question of whether an automobile stop may be extended to require production of documents may sound mundane, and even petty, but it is not. Thousands of persons drive upon the roadways daily. Further, the central purpose of constitutional provisions regarding search and seizure is to structure and limit the scope of police interference in the daily life of citizens. Generalized police discretion to engage in search and seizure is antithetical to search and seizure law. See Ochoa , 792 N.W.2d at 287.

Further, as we have noted previously, unlimited discretion to stop vehicles on the open road may give rise to allegations of racial discrimination, characterized by the descriptive phrase "driving while black." See State v. Lyon , 862 N.W.2d 391, 397 (Iowa 2015) ; see also State v. Harrison , 846 N.W.2d 362, 371–72 (Iowa 2014) (Appel, J., dissenting); Pals , 805 N.W.2d at 772 n.2 ; David A. Harris, "Driving While Black" and All Other Traffic Offenses: The Supreme Court and Pretextual Traffic Stops , 87 J. Crim. L. & Criminology 544, 546–47 (1997).

As noted in Pals , traffic stops have emerged as a major issue in search and seizure law. 805 N.W.2d at 772–73. The use of minor traffic violations as a springboard into consent searches has prompted charges of abuse and racial profiling. Id. at 772 ; see also Barbara C. Salken, The General Warrant of the Twentieth Century? A Fourth Amendment Solution to Unchecked Discretion to Arrest for Traffic Offenses , 62 Temp. L. Rev. 221, 235–36 (1989).

Indeed, the cases dealing with automobile stops sometimes have a flavor of racial profiling. See State v. Diaz-Ruiz , 211 P.3d 836, 846 (Kan. Ct. App. 2009) (questioning credibility of officer because facts demonstrated trooper was motivated by a "desire to search the vehicle of these two Hispanic men"). As we said in Pals , we approach these issues with

due regard to the legitimate needs of law enforcement, but with a recognition that our constitutional limitations on searches and seizures by law enforcement protect fundamental values of liberty and human dignity and are a bulwark against arbitrary governmental intrusions into the lives of citizens.

805 N.W.2d at 773.

B. Scope of Issues. The parties do not dispute that stopping an automobile and detaining its occupants is a seizure under article I, section 8 and the Fourth Amendment. See Delaware v. Prouse , 440 U.S. 648, 653, 99 S.Ct. 1391, 1396, 59 L.Ed.2d 660, 667 (1979). Further, the parties do not dispute that Morris initially had sufficient reasonable suspicion under both constitutions to initiate a traffic stop under the facts and circumstances of this case. Further, the parties do not dispute that once Morris determined that Coleman was a male, the reasonable suspicion that triggered the stop was no longer present. The narrow question here, which is strictly a legal question, is whether law enforcement may extend the traffic stop by asking for a driver's license, vehicle...

To continue reading

Request your trial
56 cases
  • State v. Carter
    • United States
    • New Jersey Supreme Court
    • August 2, 2021
    ...have likewise declined to adopt Heien’s reasonable mistake of law exception under their state constitutions. See State v. Coleman, 890 N.W.2d 284, 298 n.2 (Iowa 2017) (stating that the Court's prior holding rejecting the reasonable mistake of law doctrine "under the Iowa Constitution is una......
  • State v. Price-Williams
    • United States
    • Iowa Supreme Court
    • April 22, 2022
    ...113 S.Ct. 2130 (majority opinion) (discussing two-step Terry approach).206 Terry , 392 U.S. at 27, 88 S.Ct. 1868.207 See State v. Coleman , 890 N.W.2d 284, 298 (2017) (applying Schneckloth "with teeth"); see also Cynthia Lee, Reasonableness with Teeth: The Future of Fourth Amendment Reasona......
  • State v. Wright
    • United States
    • Iowa Supreme Court
    • June 18, 2021
    ...moved away from the lockstep approach and taken a more historical approach in interpreting article I, section 8. See State v. Coleman , 890 N.W.2d 284, 296 (Iowa 2017) ("As has been thoroughly canvassed in some of our other opinions, the Iowa Supreme Court has a long history of independent ......
  • Williams v. City of Burlington
    • United States
    • U.S. District Court — Southern District of Iowa
    • January 29, 2021
    ...misplaced and the Iowa Supreme Court has a long history of independent adjudication of state constitutional issues. See State v. Coleman , 890 N.W.2d 284, 287 (Iowa 2017) (collecting cases where the Iowa Supreme Court's interpretation of state constitutional provisions has diverged from the......
  • Request a trial to view additional results
3 books & journal articles
  • Motor Vehicle Searches
    • United States
    • James Publishing Practical Law Books Archive Suppressing Criminal Evidence - 2017 Contents
    • August 4, 2017
    ...license and vehicle registration, and the court reversed itself. People v. Cummings , 46 N.E.3d 248 (Il. 2016). In State v. Coleman , 890 N.W.2d 284 (Iowa, 2017), a case with almost identical facts to Cummings , the court suppressed evidence after a similar extended detention on state const......
  • Motor vehicle searches
    • United States
    • James Publishing Practical Law Books Suppressing Criminal Evidence Fourth amendment searches and seizures
    • April 1, 2022
    ...car after resolving a parking violation and pulled it over because the car didn’t park at the first available spot. • State v. Coleman , 890 N.W.2d 284 (Iowa, 2017), held that under Iowa’s state constitution, once a traffic stop mission is completed, the stop must be terminated. See Form 6-......
  • Motor vehicle searches
    • United States
    • James Publishing Practical Law Books Archive Suppressing Criminal Evidence - 2020 Contents
    • July 31, 2020
    ...license and vehicle registration, and the court reversed itself. People v. Cummings , 46 N.E.3d 248 (Il. 2016). In State v. Coleman , 890 N.W.2d 284 (Iowa, 2017), a case with almost identical facts to Cummings , the court suppressed evidence after a similar extended detention on state const......

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT