State of Iowa v. James Gerald Deaton III
Opinion
IN THE COURT OF APPEALS OF IOWA
No. 25-0365
Filed April 15, 2026
State of Iowa, Plaintiff–Appellee,
v.
James Gerald Deaton III,
Defendant–Appellant.
Appeal from the Iowa District Court for Polk County, The Honorable Brendan Greiner, Judge.
AFFIRMED
Austin Jungblut and Natalie Shroyer (until withdrawal) of Parrish Kruidenier L.L.P., Des Moines, attorneys for appellant.
Brenna Bird, Attorney General, Anagha Dixit (until withdrawal) and Adam Kenworthy, Assistant Attorneys General, attorneys for appellee.
Considered without oral argument by Greer, P.J., Chicchelly, J., and Mullins, S.J.
Opinion by Chicchelly, J.
CHICCHELLY, Judge.
James Deaton III appeals his conviction for operating while intoxicated (OWI) after a stipulated trial on the minutes of testimony. He challenges the denial of his motion to suppress the evidence obtained during a traffic stop of his vehicle. Because the stop falls under the community caretaking exception to the warrant requirement, we affirm.
BACKGROUND FACTS AND PROCEEDINGS Sergeant Brian Kempnich of the Clive Police Department was patrolling Hickman Road in the early morning hours of October 14, 2024, when he passed a red Chevrolet Equinox driven by Deaton. Sergeant Kempnich was driving a marked law enforcement vehicle, and there were almost no other vehicles on the road at the time. Once Sergeant Kempnich was about four or five car lengths ahead of the Equinox, he saw its high beams flashing in his rearview mirror. Sergeant Kempnich estimated that the Equinox’s high beams flashed between ten and fifteen times, which he found unusual. Concerned that the driver needed help, Sergeant Kempnich slowed to let the Equinox pass while he tried to look inside. Unable to see anything, Sergeant Kempnich activated his emergency lights and stopped the vehicle.
During the stop, Sergeant Kempnich noted signs that Deaton was intoxicated: a strong odor of an alcoholic beverage, bloodshot and watery eyes, slurred speech, and appearing “a little confused.” Deaton denied that he had been drinking but was unable to complete one field sobriety test and refused the rest. He was arrested and transported to the police department where chemical testing showed a blood alcohol content of 0.211.
The State charged Deaton with OWI. Before trial, Deaton moved to suppress all evidence obtained during the traffic stop, claiming it violated federal and state constitutional protections against warrantless searches. The State resisted, claiming that Sergeant Kempnich had probable cause to stop Deaton. Alternatively, the State argued that the traffic stop fell under the community caretaking exception to the warrant requirement. After a hearing, the district court denied Deaton’s motion under the community caretaking exception.
SCOPE AND STANDARD OF REVIEW We review the denial of a motion to suppress based on constitutional grounds de novo. State v. Cyrus, 997 N.W.2d 671, 676 (Iowa 2023). “Each case must be evaluated in light of its unique circumstances.” Id. (quoting State v. Coffman, 914 N.W.2d 240, 244 (Iowa 2018)). De novo review requires that we “review the entire record to independently evaluate the totality of the circumstances.” Id. (citation omitted). We defer to the district court’s factual findings, particularly those involving witness credibility, but we are not bound by them. Id.
DISCUSSION
The Fourth Amendment of the United States Constitution and article I, section 8 of the Iowa Constitution protect the right of the people to be free from “unreasonable searches and seizures.” Evidence obtained in violation of these provisions is inadmissible, “no matter how relevant or probative the evidence may be.” State v. Freeman, 705 N.W.2d 293, 297 (Iowa 2005) (citation omitted). Warrantless searches and seizures are per se unreasonable unless they fall under one of the exceptions to the warrant requirement. State v. Bradford, 620 N.W.2d 503, 506 (Iowa 2000).
Deaton contends the district court erred by denying his motion to suppress based on the community caretaking exception to the warrant requirement. The exception is based on the community caretaking functions of police, which are “totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal statute.” Coffman, 914 N.W.2d at 244 (quoting Cady v. Dombrowski, 413 U.S. 443, 441 (1973)). Instead, community caretaking functions involve an officer’s duty to help a citizen if the officer has a reasonable belief that the citizen may need help. Id.
The community caretaking exception follows a three-step analysis:
“(1) was there a seizure within the meaning of the Fourth Amendment?; (2) if so, was the police conduct bona fide community caretaker activity?; and (3) if so, did the public need and interest outweigh the intrusion upon the privacy of the citizen?” Id. at 245. The State concedes that the traffic stop was a seizure under the state and federal constitutions.
I. Was Sergeant Kempnich engaged in bona fide community caretaking activity when he stopped Deaton?
An officer is involved in a bona fide community caretaker activity if based on the facts available at the time of the seizure, a reasonable person would believe the officer’s actions were appropriate. Id. at 251. The supreme court has recognized three categories of conduct form bona fide community caretaking activity: “(1) the emergency aid doctrine, (2) the automobile impoundment/inventory doctrine, and (3) the ʻpublic servant’ exception.” Id. at 244. “The emergency-aid and public-servant doctrines are closely related.” Id. The difference involves the seriousness and exigency of the event:
Under the emergency aid doctrine, the officer has an immediate, reasonable belief that a serious, dangerous event is occurring. In contrast, the officer in a public servant situation might or might not believe that there is a difficulty requiring his general assistance. For example, an officer assists a motorist with a flat tire under the public servant doctrine, but an officer providing first aid to a person slumped over the steering wheel with a bleeding gash on his head acts pursuant to the emergency aid doctrine.
Id. at 244–45 (cleaned up).
The circumstances at the time Sergeant Kempnich stopped Deaton would allow a reasonable person to believe Deaton might need help. The sergeant explained that he did not see flashing high beams before passing the Equinox and that it is unusual for drivers to flash their high beams in the manner that Deaton did:
Usually people won’t sit there and continuously flash their high beams. They might flash them once or twice for whatever reason they are flashing them for, I don’t know, maybe try to see something in the road or what not, so usually when this happens, this usually means to me that somebody is trying to get my attention.[1]
1 Flashing headlights or high beams are recognized as a sign of distress or warning to other drivers. See, e.g., Sarber v. Comm’r of Pub. Safety, 819 N.W.2d 465, 469 (Minn. Ct. App. 2012) (“[I]t is a common practice for drivers to flash their high beams to warn other drivers of hazards, or to signal others to adjust their own headlights.”); State v. Gardner, 501 P.3d 925, 930 (Mont. 2022) (“Flashing one’s high beams is a common form of signal from one driver to another: to warn a driver they have forgotten to dim their brights, or to warn of hazardous roads conditions, a traffic accident, or wildlife on the road ahead.”); People v. Marquez, 563 N.Y.S.2d 987, 989 (N.Y. Sup. Ct. 1990) (“The courts have held that the use of high beam headlights is a recognized signal of distress justifying the stop of the vehicle.”); State v. Carlile, No. 17270, 1999 WL 301422, at *4 (Ohio Ct. App. May 14, 1999) (“Flashing one’s high beams is a common form of signal from one driver to another.”); cf. State v. Hilpipre, 395 N.W.2d 899, 900 (Iowa Ct. App. 1986) (noting that a police officer “flashed his high-low beams to signal the driver of the truck to stop”).
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