IA: Warrantless entry for misdemeanor charge unreasonable

The warrantless entry into defendant’s apartment for a misdemeanor charge was unreasonable. She didn’t waive her reasonable expectation of privacy by partially opening the door to respond to the officers’ knock. Her obstruction charge thereafter, however, was independent of the illegal entry. State v. Wilson, 2022 Iowa Sup. LEXIS 1 (Jan. 14, 2022):

In this case, we consider whether evidence obtained by law enforcement after a warrantless entry into an apartment for a misdemeanor charge passes constitutional muster under the Fourth Amendment to the United States Constitution and article I, section 8 of the Iowa Constitution. For the reasons below, we conclude that the warrantless entry into Wilson’s apartment to arrest her was unlawful. Therefore, evidence related to her conviction of possession of cocaine obtained from the unlawful entry must be suppressed. We also conclude, however, that Wilson’s conviction of interference with official acts is sufficiently attenuated from the unlawful entry to permit admission of evidence of her own illegal conduct under the “new crime exception” to the exclusionary rule. So, Wilson’s conviction for possession of cocaine is reversed, while her conviction of interference with official acts is affirmed.

[Note: Her obstruction was a direct result of the unreasonable entry into her home. This holding is in the interest of peaceable surrender to the forces of the law and then litigating it in court if the officers were wrong. But still; this was in her home and many people might resist. (This could go in the “go figure” category of results.)]