State of Iowa v. Carl Phillip Porter

CourtCourt of Appeals of Iowa
DecidedOctober 15, 2025
Docket24-1608
StatusPublished

This text of State of Iowa v. Carl Phillip Porter (State of Iowa v. Carl Phillip Porter) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Iowa v. Carl Phillip Porter, (iowactapp 2025).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1608 Filed October 15, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

CARL PHILLIP PORTER, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Scott County, Jeffrey D. Bert

(suppression) and Joel W. Barrows (trial), Judges.

A defendant challenges the stop of his vehicle and the sufficiency of the

evidence supporting his drug conviction. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Melinda J. Nye, Assistant

Appellate Defender, for appellant.

Brenna Bird, Attorney General, and Joseph D. Ferrentino, Assistant

Attorney General, for appellee.

Considered without oral argument by Ahlers, P.J., and Chicchelly and

Sandy, JJ. 2

AHLERS, Presiding Judge.

A police officer in a patrol vehicle approached a pickup truck that had

stopped right outside a big box retail store’s exit door—he suspected the pickup

was a getaway vehicle for a shoplifter inside the store. As soon as the patrol

vehicle approached, the pickup driver pulled away from the store. The officer

stopped the pickup and eventually discovered marijuana and methamphetamine

inside. Carl Porter was the driver and sole occupant of the pickup.

The State charged Porter with possession with intent to deliver more than

five grams of methamphetamine, failure to affix a drug tax stamp, and possession

of marijuana, second offense. Porter filed a motion to suppress alleging the vehicle

stop was unconstitutional, which the district court denied. Following a bench trial,

the court found Porter guilty of all three charges and sentenced him accordingly.

Porter appeals. He contends (1) the district court erred in denying his

motion to suppress, (2) there is insufficient evidence to establish that he intended

to deliver the methamphetamine, and (3) the guilty verdict was contrary to the

weight of the evidence. We address each issue in turn.

I. The Stop

Porter argues that the officer lacked the necessary reasonable suspicion to

initiate the stop, resulting in a violation of his Fourth Amendment and article I,

section 8 rights against unreasonable searches and seizures. Because Porter

alleges a constitutional violation, our review is de novo. State v. Bauler, 8 N.W.3d

892, 897 (Iowa 2024). With de novo review, we look at the totality of the

circumstances and defer to the district court’s findings, though we are not bound

by them. Id. 3

There is no dispute that Porter was seized when the police officer stopped

the pickup, so the Fourth Amendment of the federal Constitution and article I,

section 8 of the Iowa constitution are implicated. See id. The dispute is whether

the officer had reasonable suspicion to justify the stop. A traffic stop is reasonable

and thus constitutional if it is supported by reasonable suspicion of a crime. Id. To

determine whether an officer has reasonable suspicion, we look at all

circumstances known to the officer and decide whether those circumstances “give

rise to a reasonable belief that criminal activity may be afoot.” Id. (quoting State v.

McIver, 858 N.W.2d 699, 702 (Iowa 2015)).

Porter’s argument that the officer lacked reasonable suspicion focuses

almost entirely on Porter’s actions, but it largely ignores the surrounding

circumstances known to the officer. Those surrounding circumstances matter, so

we take some time to detail them.

Events at the same store two months before the stop of Porter’s vehicle are

key and were known to the officer at the time of the stop. On that previous

occasion, an older, dark-colored pickup dropped off a woman at the store and left.

The woman spent nearly six hours in the store collecting multiple items. She then

used her cell phone. A short time later, the same pickup pulled up to the store’s

door; the woman exited the store without paying for the merchandise and got in

the pickup; and the pickup drove off. An asset-protection employee of the store

used surveillance recordings to preserve photos of the woman and the pickup and

determine the Illinois license plate number of the pickup.

On the day police stopped Porter, the same pattern repeated. The same

pickup dropped the same woman off at the same entrance to the store and left. 4

Store employees recognized the woman and began monitoring her. A store

employee contacted police. Two officers arrived and waited, hiding out of view in

the store parking lot for several hours. The woman indiscriminately loaded

numerous items in her cart without checking prices or spending any time looking

at them. Some of the items included large duffel bags. She concealed multiples

items in the duffel bags, her personal bag, and various containers she grabbed off

the store’s shelves. She also spent over an hour in the store bathroom. All this

information—both from the prior incident and the current incident—was reported

to officers.

After eleven and one-half hours in the store, the woman used her cell phone

and began walking toward the exit door. Employees notified the officers

accordingly. A short time after the woman used her cell phone, the same pickup

pulled up to the same door of the store. One of the officers drove his patrol car

from his place of hiding toward the pickup, hoping to apprehend the woman as she

left the store but before she could get in the pickup to minimize the risk of escape.

However, as soon as the patrol vehicle came into view, and before the woman

exited the store, the pickup driver pulled away from the store and turned away from

the patrol vehicle down a row in the parking lot. The officer activated the patrol car

lights and stopped the pickup. Another officer drove his patrol vehicle nose to nose

with the pickup to block it. As noted, a subsequent search of the pickup—a search

Porter does not challenge—revealed methamphetamine and marijuana.

In support of his challenge to the constitutionality of the stop, Porter

highlights the fact that officers observed no traffic violations and had no information

that Porter knew of the shoplifting activity taking place in the store. But this 5

argument ignores the totality of the circumstances. Given the officers’ knowledge

of the pickup’s involvement as the getaway vehicle for the prior shoplifting incident,

coupled with the repetition of the same distinct conduct, it was reasonable for the

officers to develop the belief that the pickup was involved in the currently occurring

crime. Even if Porter didn’t actually know the woman was shoplifting, officers still

had reasonable suspicion to believe he was involved. As such, officers were

justified in making an investigatory stop to try to resolve ambiguity as to his

involvement. See State v. Kreps, 650 N.W.2d 636, 642 (Iowa 2002) (“The principal

function of an investigatory stop is to resolve the ambiguity as to whether criminal

activity is afoot.”). Officers are not required to rule out the possibility of innocent

behavior before briefly detaining a driver. State v. Struve, 956 N.W.2d 90, 96 (Iowa

2021). Even if it were equally probable that Porter was innocent of involvement in

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Related

State v. Grant
722 N.W.2d 645 (Supreme Court of Iowa, 2006)
State v. Adams
554 N.W.2d 686 (Supreme Court of Iowa, 1996)
State v. Kreps
650 N.W.2d 636 (Supreme Court of Iowa, 2002)
State of Iowa v. Carrie McIver
858 N.W.2d 699 (Supreme Court of Iowa, 2015)
State of Iowa v. Jeffrey John Myers
924 N.W.2d 823 (Supreme Court of Iowa, 2019)
State v. Franco
932 N.W.2d 84 (Nebraska Court of Appeals, 2019)

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