from the Iowa District Court for Jefferson County, Daniel
Kitchen, District Associate Judge.
defendant appeals her convictions for possession of
methamphetamine and marijuana. AFFIRMED.
A. Bergmann of Bergmann Law Firm, P.L.L.C., Mt. Pleasant, for
J. Miller, Attorney General, Kevin Cmelik, Tyler J. Buller,
and Kyle Hanson, Assistant Attorneys General, and Benjamin
Kenkel, Student Legal Intern, for appellee.
by Bower, C.J., and May and Greer, JJ.
Lasley-Eakins appeals from her convictions for possession of
marijuana and possession of methamphetamine. On appeal, she
challenges the district court's denial of her motion to
suppress. We affirm.
Facts and Prior Proceedings
2017, law enforcement executed a warrant at a residence in
Batavia, Iowa, in connection with a narcotics investigation.
Lasley-Eakins drove up to the residence in a Honda Accord.
When asked to produce identification, Lasley-Eakins provided
a non-driver ID. Lasley-Eakins admitted her license was
officer confirmed her license was suspended and placed her
under arrest for driving while suspended. Officers did not
provide Lasley-Eakins an opportunity to remove anything from
the vehicle, to lock and secure it at the residence, or to
arrange for someone to pick it up. Instead, they searched the
vehicle in anticipation of impoundment.
their inventory search, law enforcement found what appeared
to be marijuana, methamphetamine, and drug paraphernalia in
Lasley-Eakins's handbag. Subsequent testing confirmed
that recovered substances included marijuana and
methamphetamine. So the State charged Lasley-Eakins with
possession of both substances.
moved to suppress. She argued the search of the vehicle
violated the Fourth Amendment of the United States
Constitution and article I, section 8 of the Iowa
district court denied the motion to suppress. In its order,
the district court only referenced "the Fourth Amendment
of the United States Constitution." And the court only
cited Fourth Amendment caselaw. It made no mention of the
Iowa Constitution. Nor did it cite any case that mentioned
the Iowa Constitution.Although the order cited two Iowa
cases-State v. Huisman, 544 N.W.2d 433 (Iowa 1996),
and State v. Jackson, 542 N.W.2d 842 (Iowa
1996)-neither of those cases mentioned the Iowa Constitution.
They were both Fourth Amendment cases. See Huisman,
544 N.W.2d at 435 ("We hold the Fourth Amendment demands
the impoundment decision be made according to standardized
criteria and an administrative or caretaking reason to
impound exists."); Jackson, 542 N.W.2d at 845
("Inventory searches are a 'well-defined
exception' to the warrant requirement of the Fourth
Amendment, have nothing to do with the concept of probable
cause, and are unrelated to the formal criminal investigatory
the court denied her motion to suppress, Lasley-Eakins agreed
to a trial on the minutes. The court found ...