State of Iowa v. Jackson Samuel Nockels

• Court: Court of Appeals of Iowa
• Decided: September 17, 2025
• Docket: 24-1014
• Status: Published

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1014 Filed September 17, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

JACKSON SAMUEL NOCKELS, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Lyon County, Jessica Noll, Judge.

A defendant appeals the denial of his motion to suppress after his conviction

for first-offense operating while intoxicated. AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Maria Ruhtenberg,

Assistant Appellate Defender, for appellant.

Brenna Bird, Attorney General, and Anagha Dixit and Nicholas Siefert,

Assistant Attorneys General, and Samuel Augustyn, Student Legal Intern, for

appellee.

Considered without oral argument by Greer, P.J., and Badding and

Chicchelly, JJ. 2

BADDING, Judge.

Over the Fourth of July weekend in 2023, a deputy was on routine patrol

through the parking lot of the Grand Falls Casino. He saw two men leaving the

casino at around 1:40 a.m. “with an unsteady gait as if they were possibly

intoxicated.” The men were walking towards the employee lot, even though they

weren’t wearing employee uniforms. They got into their vehicle and drove further

into the employee lot—away from the exit. Suspecting the driver was intoxicated,

the deputy activated his emergency lights and initiated a traffic stop.

The driver was Jackson Nockels. The deputy observed that Nockels’s eyes

were “slightly red bloodshot and watery,” and he had a “moderate odor of an

alcoholic beverage emitting from his person.” After performing field sobriety tests,

the deputy transported Nockels to the sheriff’s office, where he provided a

DataMaster breath test with a result of .092%.

The State charged Nockels with operating while intoxicated, first offense.

Nockels moved to suppress the test results, arguing the deputy did not have

reasonable suspicion to initiate the traffic stop. The district court denied Nockels’s

motion stating:

The stop, in this case, occurred close to the time of night when the casino stopped serving alcohol. The officer observed the individuals walking to the vehicle with an unsteady gait. The vehicle was parked in an employee-only parking lot. Finally, the vehicle was driving abnormally in the parking lot, away from the exit. While these factors independently may not have been sufficient to initiate a stop, considering all of the factors together, there was an adequate basis for the officer to form reasonable suspicion to perform an investigatory stop. The officer had a reasonable suspicion to believe the Defendant might be operating a motor vehicle while under the influence. 3

Nockels proceeded to a bench trial on the minutes of testimony and was

found guilty of operating while intoxicated. He appeals, claiming the deputy did

not have reasonable suspicion for the traffic stop in violation of his federal and

state constitutional rights.

We review Nockels’s claim de novo, making an “independent evaluation of

the totality of the circumstances” as shown by the entire record. State v. McClain,

20 N.W.3d 488, 494 (Iowa 2025) (citation omitted). “We give deference to the

district court’s fact findings due to its opportunity to assess the credibility of the

witnesses, but we are not bound by those findings.” Id. (citation omitted).

“The Fourth Amendment [to] the United States Constitution,” as applied to

the states by the Fourteenth Amendment, “and article I, section 8 of the Iowa

Constitution protects individuals against unreasonable searches and seizures.”1

State v. Naujoks, 637 N.W.2d 101, 107 (Iowa 2001); accord State v. McNeal, 867

N.W.2d 91, 99 (Iowa 2015). “The temporary detention of a motorist during a traffic

stop is a ‘seizure,’ which is subject to the constitutional imperative that it not be

‘unreasonable’ under the circumstances.” State v. Brown, 930 N.W.2d 840, 845

(Iowa 2019) (cleaned up). “Generally, a traffic stop is reasonable when the police

have probable cause or reasonable suspicion to believe that the motorist violated

a traffic law.” Id.

1 Although Nockels cites both constitutions, he does not “argue that a standard

independent of the federal approach should be employed under the state constitution.” State v. Tyler, 830 N.W.2d 288, 291 (Iowa 2013). So we will consider the claims “simultaneously, applying the federal standards as outlined by the United States Supreme Court governing the Fourth Amendment.” State v. Warren, 955 N.W.2d 848, 859 (Iowa 2021). 4

Reasonable suspicion is established if the stopping officer had “specific and

articulable facts,” which, taken together with rational inferences from those facts,

support a reasonable belief that criminal activity may have occurred. State v.

Tague, 676 N.W.2d 197, 204 (Iowa 2004). This standard means the officer must

be able “to articulate more than an inchoate and unparticularized suspicion or

hunch of criminal activity.” State v. Kreps, 650 N.W.2d 636, 641 (Iowa 2002)

(cleaned up). “The circumstances under which the officer acted must be viewed

‘through the eyes of a reasonable and cautious police officer on the scene, guided

by his experience and training.’” Id. at 642 (citation omitted).

The deputy, who was trained to detect signs of intoxication, testified that he

initiated the traffic stop because “the gait of the individuals walking towards the

vehicle as well as the driving behaviors” led him to believe the driver was possibly

intoxicated. He said the men were “walking unsteady with a little bit of a sway . . .

consistent with someone who would be intoxicated.” The deputy also explained

that a couple of weeks before this stop, an intoxicated individual was climbing into

unlocked vehicles in the employee parking lot at the casino. He wanted “to make

sure the employees’ vehicles were not gonna . . . fall victim to that and that the

individuals who were walking there were where they were supposed to be.” The

deputy testified that he routinely patrolled the casino on weekend nights “due to

the higher percentage of criminal activity that occurred there,” especially later at

night when the casino stopped serving alcohol. He spotted Nockels and his friend

just before closing time.

Nockels challenges each of these reasons, arguing that none of them

individually give rise to anything more than “[s]imple generalized suspicion.” But 5

we “do not evaluate reasonable suspicion based on each circumstance

individually.” State v. McIver, 858 N.W.2d 699, 702 (Iowa 2015). Instead, we

“determine the existence of reasonable suspicion by considering all the

circumstances together.” Id. While missing the exit of the casino parking lot would

not be enough by itself to support reasonable suspicion, it was a relevant

consideration together with the other circumstances the deputy observed—the

men’s unsteady gait, the time of night, and the recent criminal activity in the area.

Compare id. (finding reasonable suspicion where a traffic stop occurred shortly

after the bars closed, the vehicle was stopped in the parking lot of a closed

business, and it drove over a grassy area, sidewalk, and curb when it left the lot),

with State v. Haviland, 532 N.W.2d 767, 768 (Iowa 1995) (finding an officer only

had an “inchoate and unparticularized suspicion” to stop a vehicle that was parked

in a closed business area).

Considering the totality of these circumstances, we agree with the district

court that the deputy had a reasonable suspicion that Nockels might be operating

a vehicle while intoxicated. We accordingly affirm the suppression ruling.

AFFIRMED.