On October 17, 2015, Officer Justin Brandt observed a black Lincoln Navigator at 12:30am in the City of Waterloo. Officer Brandt observed the driver accelerate at a yellow light and pass to the left of a moving vehicle before veering across the centerline. Officer Brandy also observed the driver’s license plate light not properly functioning. While following the vehicle, he ran the vehicle information for the vehicle’s registered owner – who was not the driver – and discovered the owner’s association with local gang activity. Subsequently, Officer Brandt decided the stop the vehicle. As he approached, he could smell alcohol coming from the driver, and he observed an open can of beer in the cupholder. Officer Brandt transported the driver to the police station, and the driver was charged with driving with a suspended license and operating a motor vehicle while intoxicated. The driver, Ms. Scottize Brown, filed a motion to suppress, claiming she was unlawfully subjected to a pretextual stop in violation of both article I, section 8 of the Iowa Constitution and the Fourth Amendment of the United States Constitution.
This case required the Iowa Supreme Court to decide whether a motorist who breaks a traffic law may lawfully be stopped if the officer was motivated by investigative reasons for the stop. The Defendant, Ms. Brown, argued the stop was in violation of her Constitutional rights because the officer’s reasons for the stop were not the traffic violations themselves. Some civil rights groups filed briefs in the case joining with Brown to urge the court to take a new approach to such traffic stops, such as a test by weighing the totality of the circumstances. However, the Court affirmed the district court decision in denying Defendant’s motion to suppress, because “the subjective motivations of an individual officer for making the stop are irrelevant” so long as the officer has an “objectively reasonable cause” to believe the driver violated a traffic law.
State of Iowa v. Scottize Danyelle Brown, No. 17-0367 (Iowa June 28, 2019).