State of Iowa v. Kayla Haas

930 N.W.2d 699
CourtSupreme Court of Iowa
DecidedJune 28, 2019
Docket17-1798
StatusPublished
Cited by31 cases

This text of 930 N.W.2d 699 (State of Iowa v. Kayla Haas) is published on Counsel Stack Legal Research, covering Supreme Court 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. Kayla Haas, 930 N.W.2d 699 (iowa 2019).

Opinions

PER CURIAM.

Kayla Haas was convicted of driving while barred. On appeal, Haas challenges the district court's ruling denying her motion to suppress on the grounds she was subject to an impermissible pretextual seizure. She also challenges the reasonable suspicion of her stop. Further, Haas argues her counsel was ineffective and the district court improperly assessed court costs and attorney fees. We retained Haas's appeal.

As to Haas's challenge of her denied motion to suppress, we affirm the district court's denial. "When a defendant challenges a district court's denial of a *702motion to suppress based upon the deprivation of a state or federal constitutional right, our standard of review is de novo." State v. Coffman , 914 N.W.2d 240, 244 (Iowa 2018) (quoting State v. Storm , 898 N.W.2d 140, 144 (Iowa 2017) ). In State v. Brown , 930 N.W.2d 840, ----, 2019 WL 2710809 (Iowa 2019), we determined the subjective motivations of an individual officer in making a traffic stop under article I, section 8 of the Iowa Constitution are irrelevant as long as the officer has objectively reasonable cause to believe the motorist violated a traffic law. There, consistent with precedent in Iowa, we affirmed the district court's determination that the subjective reasoning in the decision to stop the motorist did not matter because the officer objectively observed traffic violations.

We also affirm the district court judgment on Haas's second challenge, whether her stop was supported by reasonable suspicion. The standard of review for a constitutional search and seizure challenge is de novo. State v. Vance , 790 N.W.2d 775, 780 (Iowa 2010). We do not believe the officers violated article I, section 8 of the Iowa Constitution when they stopped Haas based on reasonable suspicion that she was driving while barred. At the very least, the officers had reasonable suspicion to stop Haas's vehicle after they observed her and two other people getting into the vehicle before leaving the area.

A traffic stop is generally reasonable, and thus constitutional under state and federal search and seizure provisions, if the police have probable cause or reasonable suspicion to believe that the motorist violated a traffic law. Navarette v. California , 572 U.S. 393, 401-02, 134 S. Ct. 1683, 1690, 188 L.Ed.2d 680 (2014) ; Whren v. United States , 517 U.S. 806, 809-10, 116 S. Ct. 1769, 1772, 135 L.Ed.2d 89 (1996) ; State v. Tague , 676 N.W.2d 197, 204 (Iowa 2004). In Vance , we held reasonable suspicion existed to support a traffic stop to investigate the validity of the motorist's driver's license "when the officer knows the registered owner of the vehicle has a suspended license, and the officer is unaware of any evidence or circumstances indicating the registered owner is not the driver of the vehicle." 790 N.W.2d at 781. In doing so, we explained, "[I]t is reasonable for an officer to infer the registered owner of the vehicle will do the vast amount of the driving." Id. Thus, "it is sufficiently reasonable to generate reasonable suspicion for an investigatory stop to resolve the ambiguity as to whether criminal activity is afoot." Id. at 781-82. Yet, we also noted that reasonable suspicion would disappear if the officer obtained information suggesting that the driver is not the owner of the vehicle. Id. at 782.

Haas claims the police were aware of circumstances that invalidated their assumption that Haas was driving the vehicle when they made the traffic stop. Namely, Haas points out that the officers in this case did not know her and observed three people enter the vehicle but did not see which of the three was driving. However, these circumstances do not invalidate the officers' assumption that Haas was driving her own vehicle when they made the traffic stop.

Prior to initiating the traffic stop, the officers ran the license plate of the vehicle. They identified Haas as the registered owner and discovered that she had a suspended license. Soon after, the officers saw a woman that "appeared to be" Haas and two males leave the residence they were observing. Though the officers did not see who was driving the vehicle, it was still reasonable to assume that Haas, as the registered owner of the vehicle, would be doing "the vast amount of the driving." Id. at 781.

*703We upheld the reasonableness of the search in Vance

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Cite This Page — Counsel Stack

Bluebook (online)
930 N.W.2d 699, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-iowa-v-kayla-haas-iowa-2019.