IN THE COURT OF APPEALS OF IOWA
No. 24-0154 Filed July 23, 2025
STATE OF IOWA, Plaintiff-Appellee,
vs.
RYAN SCOTT PEARSON, Defendant-Appellant. ________________________________________________________________
Appeal from the Iowa District Court for Scott County, Cheryl Traum, Judge.
A defendant appeals his convictions after a conditional guilty plea,
challenging the district court’s denial of his motion to suppress. AFFIRMED.
Martha J. Lucey, State Appellate Defender, and Melinda J. Nye, Assistant
Appellate Defender, for appellant.
Brenna Bird, Attorney General, and Joshua Henry, Assistant Attorney
General, for appellee.
Considered without oral argument by Greer, P.J., and Buller and
Langholz, JJ. 2
LANGHOLZ, Judge.
Early one morning, a police officer saw Ryan Pearson passed out behind
the wheel of his idling truck in a casino parking garage. Pearson’s truck was
unlocked and what appeared to be a handgun was visible on the passenger seat.
Concerned, the officer called for backup, blocked in the truck, roused him awake,
and removed him from the vehicle. It quickly became clear Pearson was impaired,
so he was taken to the police station for further investigation. After he was
criminally charged with operating a motor vehicle while intoxicated and possessing
a dangerous weapon while intoxicated, he moved to suppress all the evidence
arising out of his encounter with law enforcement that morning, arguing he was
unconstitutionally seized. The district court denied the motion, holding that the
community-caretaking exception authorized the seizure. Pearson and the State
agreed to a conditional guilty plea, preserving the suppression issue for appeal.
Because Pearson’s appeal presents the same issue reserved by his plea
and success on appeal would afford some relief, our interest-of-justice
jurisdictional requirement is satisfied. And on the merits, we agree with the district
court that Pearson’s warrantless seizure falls within the community-caretaking
exception. The officer’s testimony during the suppression hearing shows he was
subjectively motivated to check on Pearson’s wellbeing. Concern for the safety of
a driver who is passed out next to a handgun is objectively reasonable. And the
intrusion into Pearson’s privacy was not so great as to outweigh the substantial
public interest in securing a firearm within an unlocked vehicle and preventing a
drowsy or intoxicated driver from driving onto public roadways. We thus affirm the
district court’s suppression ruling and Pearson’s conviction. 3
I.
Around 1:30 a.m. on February 4, 2023, a Bettendorf police officer noticed a
pickup truck idling in a parking spot in a casino parking garage. The truck was
backed into the spot and was running with its headlights on. A man—Pearson—
was asleep in the driver’s seat. The officer approached the truck and saw a
handgun in the passenger seat.1 And the truck’s doors were unlocked. The officer
was concerned and decided to “check on him,” as “typically people don’t sleep with
a handgun next to them and their car unlocked.”
The officer waited for backup to arrive, and a police vehicle parked in front
of Pearson’s truck, which was customary to ensure Pearson did not accidentally
drive the truck forward and injure himself or someone else upon waking. The
officer then opened the driver’s side door and roused Pearson. The smell of
alcohol was immediately present. The officer guided Pearson out of the vehicle
and observed Pearson with bloodshot, watery eyes. So the officer performed the
horizontal gaze nystagmus test, which indicated Pearson was impaired.
Pearson was handcuffed and transported to the police station for further
testing. At the station, Pearson mentioned taking a prescription medication earlier
that day. Officers then obtained a search warrant, which allowed them to collect a
blood sample from Pearson. And based on the results, Pearson was charged with
operating while intoxicated, third offense, and possession of a dangerous weapon
while intoxicated. See Iowa Code §§ 321J.2, 724.4C (2023).
1 Pearson later gave officers consent to search his truck, which confirmed the gun
on the seat was a BB gun and that another legitimate handgun was also present in the vehicle. 4
Pearson moved to suppress all the evidence arising out of his initial
encounter with law enforcement—including the blood specimen—arguing he was
unlawfully seized under both the United States and Iowa Constitutions. The State
justified the seizure under both the community-caretaking exception and based on
reasonable suspicion of intoxication. And the court denied Pearson’s motion,
agreeing that the seizure was lawful under both of the State’s theories.
Pearson later entered a conditional guilty plea to both charges, wherein he
and the State agreed to reserve the suppression issue for appeal. Pearson was
sentenced to two years in prison, with all but seven days suspended. He now
appeals his conviction, challenging the denial of his suppression motion.
II.
To begin, because Pearson appeals from a conditional guilty plea, we must
assure ourselves of appellate jurisdiction. See Iowa Code § 814.6(3). We have
jurisdiction over a conditional guilty plea reserving an issue for appeal only when
“entered by the court with the consent of the prosecuting attorney and the
defendant or the defendant’s counsel” and “when the appellate adjudication of the
reserved issue is in the interest of justice.” Id. Because Pearson’s appeal of the
suppression ruling “is the same issue reserved by the conditional guilty plea, and
success on appeal of that issue would give [Pearson] some relief,” the interest-of-
justice jurisdictional threshold is satisfied. State v. Scullark, __ N.W.3d __, 2025
WL 1717213, at *2 (Iowa 2025). We thus have jurisdiction to proceed to the merits,
reviewing the district court’s suppression ruling de novo. State v. Coffman, 914
N.W.2d 240, 244 (Iowa 2018). 5
Both our federal and state constitutions protect against unreasonable
searches and seizures. U.S. Const. amend. IV, Iowa Const. art. I, § 8. Warrantless
searches and seizures “are per se unreasonable if they do not fall within one of the
well-recognized exceptions to the warrant requirement.” State v. Tyler, 867
N.W.2d 136, 169 (Iowa 2015) (cleaned up). One such exception is community
caretaking. State v. Abu Youm, 988 N.W.2d 713, 718 (Iowa 2023). This exception
is grounded not in the routine investigative functions of law enforcement but turns
on the duty “to help citizens an officer reasonably believes may be in need of
assistance.” Tyler, 867 N.W.2d at 170 (cleaned up).
We apply the community-caretaking exception when (1) there was a
constitutional seizure, (2) officers were engaged in bona fide community-
caretaking activity, and (3) the public interest outweighed the intrusion on the
citizen’s privacy. Id. Still, “[e]very community caretaking case must be assessed
according to its own unique set of facts and circumstances because
reasonableness is not a term that can be usefully refined in order to evolve some
detailed formula for judging cases.” State v.
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IN THE COURT OF APPEALS OF IOWA
No. 24-0154 Filed July 23, 2025
STATE OF IOWA, Plaintiff-Appellee,
vs.
RYAN SCOTT PEARSON, Defendant-Appellant. ________________________________________________________________
Appeal from the Iowa District Court for Scott County, Cheryl Traum, Judge.
A defendant appeals his convictions after a conditional guilty plea,
challenging the district court’s denial of his motion to suppress. AFFIRMED.
Martha J. Lucey, State Appellate Defender, and Melinda J. Nye, Assistant
Appellate Defender, for appellant.
Brenna Bird, Attorney General, and Joshua Henry, Assistant Attorney
General, for appellee.
Considered without oral argument by Greer, P.J., and Buller and
Langholz, JJ. 2
LANGHOLZ, Judge.
Early one morning, a police officer saw Ryan Pearson passed out behind
the wheel of his idling truck in a casino parking garage. Pearson’s truck was
unlocked and what appeared to be a handgun was visible on the passenger seat.
Concerned, the officer called for backup, blocked in the truck, roused him awake,
and removed him from the vehicle. It quickly became clear Pearson was impaired,
so he was taken to the police station for further investigation. After he was
criminally charged with operating a motor vehicle while intoxicated and possessing
a dangerous weapon while intoxicated, he moved to suppress all the evidence
arising out of his encounter with law enforcement that morning, arguing he was
unconstitutionally seized. The district court denied the motion, holding that the
community-caretaking exception authorized the seizure. Pearson and the State
agreed to a conditional guilty plea, preserving the suppression issue for appeal.
Because Pearson’s appeal presents the same issue reserved by his plea
and success on appeal would afford some relief, our interest-of-justice
jurisdictional requirement is satisfied. And on the merits, we agree with the district
court that Pearson’s warrantless seizure falls within the community-caretaking
exception. The officer’s testimony during the suppression hearing shows he was
subjectively motivated to check on Pearson’s wellbeing. Concern for the safety of
a driver who is passed out next to a handgun is objectively reasonable. And the
intrusion into Pearson’s privacy was not so great as to outweigh the substantial
public interest in securing a firearm within an unlocked vehicle and preventing a
drowsy or intoxicated driver from driving onto public roadways. We thus affirm the
district court’s suppression ruling and Pearson’s conviction. 3
I.
Around 1:30 a.m. on February 4, 2023, a Bettendorf police officer noticed a
pickup truck idling in a parking spot in a casino parking garage. The truck was
backed into the spot and was running with its headlights on. A man—Pearson—
was asleep in the driver’s seat. The officer approached the truck and saw a
handgun in the passenger seat.1 And the truck’s doors were unlocked. The officer
was concerned and decided to “check on him,” as “typically people don’t sleep with
a handgun next to them and their car unlocked.”
The officer waited for backup to arrive, and a police vehicle parked in front
of Pearson’s truck, which was customary to ensure Pearson did not accidentally
drive the truck forward and injure himself or someone else upon waking. The
officer then opened the driver’s side door and roused Pearson. The smell of
alcohol was immediately present. The officer guided Pearson out of the vehicle
and observed Pearson with bloodshot, watery eyes. So the officer performed the
horizontal gaze nystagmus test, which indicated Pearson was impaired.
Pearson was handcuffed and transported to the police station for further
testing. At the station, Pearson mentioned taking a prescription medication earlier
that day. Officers then obtained a search warrant, which allowed them to collect a
blood sample from Pearson. And based on the results, Pearson was charged with
operating while intoxicated, third offense, and possession of a dangerous weapon
while intoxicated. See Iowa Code §§ 321J.2, 724.4C (2023).
1 Pearson later gave officers consent to search his truck, which confirmed the gun
on the seat was a BB gun and that another legitimate handgun was also present in the vehicle. 4
Pearson moved to suppress all the evidence arising out of his initial
encounter with law enforcement—including the blood specimen—arguing he was
unlawfully seized under both the United States and Iowa Constitutions. The State
justified the seizure under both the community-caretaking exception and based on
reasonable suspicion of intoxication. And the court denied Pearson’s motion,
agreeing that the seizure was lawful under both of the State’s theories.
Pearson later entered a conditional guilty plea to both charges, wherein he
and the State agreed to reserve the suppression issue for appeal. Pearson was
sentenced to two years in prison, with all but seven days suspended. He now
appeals his conviction, challenging the denial of his suppression motion.
II.
To begin, because Pearson appeals from a conditional guilty plea, we must
assure ourselves of appellate jurisdiction. See Iowa Code § 814.6(3). We have
jurisdiction over a conditional guilty plea reserving an issue for appeal only when
“entered by the court with the consent of the prosecuting attorney and the
defendant or the defendant’s counsel” and “when the appellate adjudication of the
reserved issue is in the interest of justice.” Id. Because Pearson’s appeal of the
suppression ruling “is the same issue reserved by the conditional guilty plea, and
success on appeal of that issue would give [Pearson] some relief,” the interest-of-
justice jurisdictional threshold is satisfied. State v. Scullark, __ N.W.3d __, 2025
WL 1717213, at *2 (Iowa 2025). We thus have jurisdiction to proceed to the merits,
reviewing the district court’s suppression ruling de novo. State v. Coffman, 914
N.W.2d 240, 244 (Iowa 2018). 5
Both our federal and state constitutions protect against unreasonable
searches and seizures. U.S. Const. amend. IV, Iowa Const. art. I, § 8. Warrantless
searches and seizures “are per se unreasonable if they do not fall within one of the
well-recognized exceptions to the warrant requirement.” State v. Tyler, 867
N.W.2d 136, 169 (Iowa 2015) (cleaned up). One such exception is community
caretaking. State v. Abu Youm, 988 N.W.2d 713, 718 (Iowa 2023). This exception
is grounded not in the routine investigative functions of law enforcement but turns
on the duty “to help citizens an officer reasonably believes may be in need of
assistance.” Tyler, 867 N.W.2d at 170 (cleaned up).
We apply the community-caretaking exception when (1) there was a
constitutional seizure, (2) officers were engaged in bona fide community-
caretaking activity, and (3) the public interest outweighed the intrusion on the
citizen’s privacy. Id. Still, “[e]very community caretaking case must be assessed
according to its own unique set of facts and circumstances because
reasonableness is not a term that can be usefully refined in order to evolve some
detailed formula for judging cases.” State v. Kurth, 813 N.W.2d 270, 277 (Iowa
2012) (cleaned up).
Pearson was seized. In the district court, the State did “not contest a seizure
occurred within the meaning of the Fourth Amendment” and instead focused its
resistance on the exception’s latter two prongs. On appeal, the State similarly
does not contest that Pearson was seized but disputes the precise moment of
seizure and whether reasonable suspicion had materialized by then. Because we
need not resolve this dispute, we assume without deciding that Pearson was
seized when the officers blocked in his car and proceed to the second prong. 6
Officers engaged in bona fide community-caretaking activity. Community-
caretaking activity generally falls within three recognized categories: rendering
emergency aid, impounding or inventorying an automobile, and performing public-
servant duties. Id. at 277. The first and third categories could apply here, and the
two are “analytically similar.” Coffman, 914 N.W.2d at 245. To illustrate the
distinction, “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. (cleaned up). Under the Fourth Amendment, we decide whether the
officer is engaged in community caretaking under either category objectively
“based on the information available at the time of the” seizure. Id. at 257. But
under the Iowa Constitution, the State carries the burden “to prove both that the
objective facts satisfy the standards for community caretaking and that the officer
subjectively intended to engage in community caretaking.” Id.
Pearson insists that merely catching some sleep did not justify officer
intervention, but we have little trouble finding bona fide community-caretaking
activity here. First, the officer’s testimony showed he was subjectively motivated
to “check on” Pearson after observing him passed out next to a handgun early in
the morning in a casino parking garage. Second, concern for Pearson’s safety
was objectively reasonable—checking on an unresponsive person in a running
vehicle is both “justifiabl[e]” and “commendable” law enforcement conduct. State
v. Kersh, 313 N.W.2d 566, 568–69 (Iowa 1981), abrogated on other grounds by
State v. Lake, 476 N.W.2d 55, 56–57 (Iowa 1991). That the officer later turned his
attention to Pearson’s possible intoxication does not negate the initial existence of 7
a community-caretaking function, as Pearson urges. And third, Pearson’s position
that he was merely sleeping ignores the other heightening facts on the scene—a
visible handgun in an unlocked vehicle. Thus, the officers acted firmly within the
bounds of community-caretaking functions.
Public interest outweighed any privacy intrusion. Finally, we find the
constitutional balance between the public interest and the intrusion upon Pearson’s
privacy tips in favor of applying the exception. The public necessity of securing a
firearm within an intoxicated driver’s vehicle was the impetus of the community-
caretaking doctrine. See Cady v. Dombrowski, 413 U.S. 433, 447 (1973).
Weighed against that substantial public safety interest is Pearson’s reduced
expectation of privacy within his vehicle. See State v. Brown, 930 N.W.2d 840,
853 (Iowa 2019). And any intrusion was minimal and appropriately cabined to the
steps necessary to protect Pearson and others—rousing him awake, blocking his
truck to ensure he could not drive onto public roadways in his either drowsy or
impaired state, and distancing him from the handgun. Thus, finding all three
elements satisfied, we affirm the denial of Pearson’s suppression motion and his
convictions.
AFFIRMED.