State v. Pals
Annotate this CaseRandall Pals' vehicle was searched during a traffic stop to investigate an ongoing minor infraction of a municipal ordinance. The police officer discovered marijuana. Pals moved to suppress the evidence, challenging the legality of the traffic stop and search. The district court denied the motion, and Pals was convicted of possession of a controlled substance. The court of appeals affirmed. The Supreme Court vacated the court of appeals and reversed the district court, holding that the district court erred by refusing to grant Pals' suppression motion where (1) the police officer had probable cause to believe that Pals was committing an ongoing civil offense, and therefore, the initial traffic stop was legal; but (2) pursuant to an application of the Iowa version of the U.S. Supreme Court's Schneckloth v. Bustamonte totality of the circumstances test, Pals' consent to search his vehicle was not voluntarily under the Iowa Constitution. Remanded.
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