State of Iowa v. Laub
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In the state of Iowa, a police officer investigated a suspected case of driving a motor vehicle while intoxicated. The officer pulled over the suspect, Colby Laub, and obtained a search warrant to collect a breath specimen for chemical testing after Laub refused to participate in field sobriety testing. The chemical testing showed that Laub had a blood alcohol content well above the legal limit, and he was subsequently arrested. Laub moved to suppress the evidence of the chemical breath test, as well as statements he had made to the officer, arguing that the officer was required to invoke the statutory implied consent procedure and give him the opportunity to refuse to provide a sample, rather than proceed with a search warrant. The district court agreed with Laub and granted his motion on the grounds that the officer had no statutory authority to obtain a search warrant to collect and test bodily specimens, and that doing so violated Laub's constitutional rights to equal protection and due process. The state appealed this decision.
The Supreme Court of Iowa reversed the district court's decision. The court found that the district court erred in holding that the statutory implied consent procedure is the only way a law enforcement officer can obtain a bodily specimen and conduct chemical testing in investigating an OWI case. The court noted that the officer's decision to obtain a search warrant instead of invoking the statutory implied consent procedure did not violate the defendant's rights to equal protection or due process. The court also disagreed with the district court's interpretation of the statute, stating that the statutory implied consent law is not the exclusive means by which a law enforcement officer can obtain a breath sample in an OWI case. Therefore, the court reversed the district court's suppression ruling and remanded the case for further proceedings.
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