Iowa’s cases from Thursday

There was probable cause based on the dashcam video for defendant’s stop for not having two functioning headlights. “Here, what the video evidence shows is unquestionably open to interpretation as to whether the headlight was inoperable or just dim. Whatever the case, the dash cam footage from Chia’s patrol car that was admitted as evidence at the suppression hearing, while not explicitly clear on whether the headlamp was unlit or merely ‘just dimmer,’ unquestionably shows the suspect headlamp was not functioning as designed to.” State v. Howard, 2020 Iowa App. LEXIS 85 (Jan. 23, 2020).*

Defendant’s stop occurred because, as they followed, officers saw the license plate not properly lighted. Defendant was also being evasive. A rifle was obvious in the back, and officers quickly determined it was an airsoft gun. However, two pistol magazines were then seen, too. Finally, through all this, marijuana was seen at the side of the road that wasn’t there shortly before. A search was reasonable. State v. Erdman, 2020 Iowa App. LEXIS 107 (Jan. 23, 2020).*

Defendant was in a car that was stopped because a license plate wasn’t visible, but it turned out there was one in the rear window. Once stopped, there were furtive movements, one tried to walk away, and a struggle ensued. It wasn’t unreasonable for the officer’s attention to be directed at defendant. State v. Tillman, 2020 Iowa App. LEXIS 86 (Jan. 23, 2020).*

Defendant’s pro se supplemental brief on appeal argues that the search of the back seat of the police car was unreasonable. That’s not preserved for appellate review [and it is hardly even remotely plausible because police don’t need a search warrant to look for abandoned property in a police car]. State v. Smith, 2020 Iowa App. LEXIS 90 (Jan. 23, 2020).*