IA: Iowa requires a search warrant for a probation search

Iowa requires a search warrant for a probation search. State v. Sacco, 2014 Iowa App. LEXIS 945 (October 1, 2014):

The State asserts the legality of the search at issue here is “controlled by Griffin.” In regard only to Sacco’s federal constitutional claim, we agree with the State that the search was supported by sufficient information to satisfy the United States Supreme Court’s lowered burden for searches of probationers and parolees. Griffin, 483 U.S. at 879-80.

However, because the Iowa Constitution provides superior protections for probationers than does the federal constitution, the State’s reliance on Griffin does not satisfy our state’s unique constitutional requirements. The Iowa Constitution required a warrant—and probable cause—for the search of Sacco’s home.