State of Iowa v. Justin Curtis Welch

CourtCourt of Appeals of Iowa
DecidedApril 1, 2026
Docket25-0445
StatusPublished

This text of State of Iowa v. Justin Curtis Welch (State of Iowa v. Justin Curtis Welch) 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. Justin Curtis Welch, (iowactapp 2026).

Opinion

IN THE COURT OF APPEALS OF IOWA _______________

No. 25-0445 Filed April 1, 2026 _______________

State of Iowa, Plaintiff–Appellee, v. Justin Curtis Welch, Defendant–Appellant. _______________

Appeal from the Iowa District Court for Polk County, The Honorable Ashley Stewart, Judge. _______________

AFFIRMED _______________

Colin Murphy of Gourley Rehkemper Lindholm, P.L.C., West Des Moines, attorney for appellant.

Brenna Bird, Attorney General, and Louis S. Sloven, Assistant Attorney General, attorneys for appellee. _______________

Considered without oral argument by Tabor, C.J., Langholz, J., and Bower, S.J. Opinion by Tabor, C.J.

1 TABOR, Chief Judge.

Convicted of operating while intoxicated, Justin Welch challenges the district court’s denial of his motion to suppress. He contends a state trooper lacked reasonable suspicion to stop his work truck and investigated based on a mistake of law. Welch also argues the trooper unconstitutionally prolonged the traffic stop. Because Welch did not preserve his first claim in the district court, we do not consider the legality of the stop. And because the trooper developed reasonable suspicion to continue his investigation, we affirm the district court’s suppression ruling.

I. Background and Prior Proceedings

Trooper Justin Mack has served on the Iowa State Patrol’s commercial motor vehicle unit for thirteen years. He describes his job as “the inspection of commercial vehicles, both inter- and intrastate inspection of both driver qualifications and vehicle equipment on the commercial vehicles traveling up and down the roadways through the state of Iowa.”

While Trooper Mack was on night duty in August 2024, he noticed a large Chevy truck parked at a gas station. Given its size, the truck “appeared to be a commercial vehicle.”1 Welch sat in the driver’s seat for several minutes, holding the door open with his foot. This “struck [Trooper Mack] as a little out of place.” Welch entered the gas station and came out with a

1 The vehicle “[h]ad a dually set of tires on the back axle, so four tires on the rear end” and had “a large dump bed on it.” Based on his training and experience, Trooper Mack knew it was over 10,000 pounds. A commercial vehicle is defined as “a vehicle or combination of vehicles designed principally to transport passengers or property of any kind if . . . [t]he vehicle or any combination of vehicles has a gross vehicle weight rating or gross combination weight rating of ten thousand one or more pounds.” Iowa Code § 321.1(12)(b) (2024).

2 brown paper bag. Trooper Mack testified, “In my experience, when you’re leaving a convenience store with a brown paper bag, usually that happens to be alcohol.” Welch returned to his vehicle and drove away.

Trooper Mack followed and pulled Welch over. Welch told the trooper that he worked for a lawn care business and was heading home after finishing a job. After determining the truck was an intrastate commercial vehicle, the trooper began a level III inspection.2 He asked for Welch’s paperwork and inquired what he bought at the gas station. The brown paper bag contained a sandwich and Gatorade. Trooper Mack testified he asks the same set of questions during his inspections, including inquiries on alcohol, drugs, and weapons. When he asked about alcohol in the truck, at first a “very jittery” Welch denied having any. But Trooper Mack persisted: “Are you sure? What about that cooler sitting on the floor?” Welch then admitted possessing alcohol, as the trooper found empty “Twisted Teas” in the cooler.

When he asked about drug use, Trooper Mack noted Welch’s body language. Welch appeared “very rigid, very shaky” as he spoke with the trooper. Again, Welch denied the presence of drugs when first asked. But upon further questioning, Welch admitted he had drugs in the truck. Concerned about federal and state regulations for commercial vehicles, as

2 The trooper detailed three levels of inspection. A level III inspection is a “driver inspection,” which Trooper Mack described as “checking the qualifications of the driver. Does the driver need a medical card? Do they need a logbook? Do they have the presence of drugs and alcohol?” Two exhibits admitted at the suppression hearing outlined that a level III inspection included inspecting for “traffic violations/infractions,” and observing “the driver’s overall condition . . . for illness, fatigue or other signs of impairment.” The trooper added: “In a Level II inspection, we do everything that’s involved in a Level III, plus lights. And then in a Level I inspection, we do everything involved in a Level III, a Level II, but then we add brakes.”

3 well as the driver’s potential impairment, Trooper Mack began field sobriety testing and called for help from a drug recognition expert (DRE).3

The State charged Welch with unlawful possession of a prescription drug, operating while intoxicated, and possession of a controlled substance. Welch moved to suppress evidence, challenging the grounds for the stop and his prolonged detention. On the eve of the suppression hearing, the State filed a resistance to the motion to suppress, urging that reasonable suspicion was not required to stop a commercial motor vehicle for inspection. See Iowa Code § 321.476. The district court denied his motion.

Welch entered a conditional guilty plea to the second count, and the State dismissed the first and third count. In appealing his conviction, Welch challenges the district court’s denial of his motion to suppress.4

II. Analysis

“We review the district court’s denial of a motion to suppress based on deprivation of a constitutional right de novo.” State v. Arrieta, 998 N.W.2d 617, 620 (Iowa 2023). “We give deference to the district court’s findings of fact, but we are not bound by them.” Id.

Welch raises two issues. First, he contends Trooper Mack based the traffic stop on a mistake of law. Welch asserts that because he was only operating the truck in intrastate commerce, the federal regulations on

3 A report from that DRE, Trooper Allison Fleming, revealed the presence of Adderal, marijuana, and Xanax, and that Welch was having heroin withdrawal. In Trooper Fleming’s opinion, Welch was under the influence of cannabis and a CNS (central nervous system) stimulant and “unable to operate a motor vehicle safely.” 4 The parties agree that we have jurisdiction to consider this appeal. See State v. Scullark, 23 N.W.3d 49, 53 (Iowa 2025) (discussing Iowa Code section 814.6).

4 commercial vehicles adopted under Iowa Code section 321.449 did not apply to him. Second, Welch argues Trooper Mack prolonged the stop without reasonable suspicion to support more investigation.

We decline to reach the merits of Welch’s first argument because he did not preserve it before the district court. Granted, he now presents an interesting question on whether commercial vehicles operating exclusively intrastate are exempt from the alcohol prohibition under 49 C.F.R. section 392.5. See Iowa Code § 321.449 (1), (2), (4). But Welch’s arguments at the suppression hearing focused on whether the trooper had reasonable suspicion to stop him.5 Welch did not allege that the trooper made a mistake of law in stopping him nor did he obtain a ruling on that ground.6 Thus, the State’s justification for the stop—as a permissible inspection of a commercial vehicle—stands because Welch did not preserve his argument attacking that justification. See State v.

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Related

State v. Marks
644 N.W.2d 35 (Court of Appeals of Iowa, 2002)
In the Matter of Property Seized From Robert Pardee, Robert Pardee
872 N.W.2d 384 (Supreme Court of Iowa, 2015)

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State of Iowa v. Justin Curtis Welch, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-justin-curtis-welch-iowactapp-2026.