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Full Opinion
In the Iowa Supreme Court
No. 23â0480
Submitted November 19, 2024âFiled December 20, 2024
State of Iowa,
Appellee,
vs.
Artell Jamario Young,
Appellant.
Appeal from the Iowa District Court for Polk County, William P. Kelly,
judge.
A defendant appeals his convictions for various drug offenses, arguing that
the search of his home by federal probation officers violated article I, section 8
of the Iowa Constitution. Affirmed.
Mansfield, J., delivered the opinion of the court in which all justices joined.
Martha J. Lucey, State Appellate Defender, and Melinda J. Nye (argued),
Assistant Appellate Defendant, for appellant.
Brenna Bird, Attorney General, and Louis S. Sloven (argued), Assistant
Attorney General, for appellee.
2
Mansfield, Justice.
I. Introduction.
Two stars keep not their motion in one sphere;
Nor can one England brook a double reign.
William Shakespeare, Henry IV Part I, act 5, sc. 4, l. 3019â20.
The genius of our federal system is that it does âbrook a double reign.â Our
citizens are governed by two sovereigns: state and federal. This system has
served America well, but it results in considerable work for judges, who must
decide which sovereignâs law to apply when a case involves the acts of both.
An individual who was under federal supervised release agreed that he
would submit to searches of his person, vehicle, or home if federal probation
officers had reasonable suspicion to believe that those areas contained
contraband or that he had violated the terms of his release. After receiving
information that the individual was illegally dealing drugs and illegally
possessing a firearm, federal probation officers conducted a search of his home,
where they discovered relatively small amounts of crack cocaine, powdered
cocaine, and marijuana. Concluding that this level of criminal activity was more
that of a Falstaff than a Hotspur, the federal authorities turned the matter over
to Iowa authorities. Compare William Shakespeare, Henry IV Part I, act 1, sc. 2,
with id. act 1, sc. 3. Charges were brought, and the individual was convicted of
several aggravated misdemeanor drug offenses. He now appeals, claiming that
the search of his home by federal probation officers violated Iowa constitutional
standards but not claiming that it violated federal standards.
We conclude that the constitutionality of the search should be evaluated
by the law of the sovereign that initiated and conducted the searchânot by the
law of the sovereign that had nothing to do with the search. We therefore reject
the defendantâs claim of an illegal search and affirm his convictions.
3
II. Facts and Procedural History.
Artell Young, whose criminal history includes convictions for state
weapons offenses from 2008, 2014, and 2016, was convicted of the federal crime
of felon in possession of a firearm in federal district court in February 2017. See
18 U.S.C. §§ 922(g)(1), 924(a)(2). He received a prison sentence. Following his
discharge from prison in January 2019, Young had to undergo a
thirty-six-month period of supervised release.1 He was assigned to United States
Probation Officer Amy Johnson. A condition of Youngâs supervised release
authorized him to be searched by federal probation officers:
You will submit to a search of your person, property,
residence, adjacent structures, office, vehicle, papers, computers (as
defined in 18 U.S.C. § 1030(e)(1)), and other electronic
communications or data storage devices or media, conducted by a
U.S. Probation Officer. Failure to submit to a search may be grounds
for revocation. You must warn any other residents or occupants that
the premises and/or vehicle may be subject to searches pursuant to
this condition. An officer may conduct a search pursuant to this
condition only when reasonable suspicion exists that you have
violated a condition of your release and/or that the area(s) or item(s)
to be searched contain evidence of this violation or contain
contraband. Any search must be conducted at a reasonable time
and in a reasonable manner. This condition may be invoked with or
without the assistance of law enforcement, including the U.S.
Marshals Service.
In February 2021, Officer Johnson received information from a
confidential source that Young was selling controlled substances. The source
also reported seeing Young in possession of a black handgun on at least two
separate occasions. Reportedly, the gun was owned by Youngâs wife, Jasmine
Evans, but the source had observed Young handling it.
1See United States v. Makeeff, No. 4:14âcrâ00081âSMRâCFB, 2015 WL 13284966, at *4
(S.D. Iowa Feb. 6, 2015) (âThe Court must first note that this case involves federal supervised
release, not probation or parole. Supervisees, in a sense, enjoy the least amount of privacy in
this context.â), affâd, 820 F.3d 995 (8th Cir. 2016) (per curiam).
4
In September, Young was arrested for operating a motor vehicle while
intoxicated. See Iowa Code § 321J.2 (2021). Then, in November, the same
confidential source informed Officer Johnson that they saw Young receiving
drugs and telling people that he was cooking cocaine.
Officer Johnson submitted a formal search request to the search
coordinator for the judicial districtâUnited States Probation Officer Justin Song.
The purpose of the search was to look for â[e]vidence of a violation of [Youngâs]
conditions which includes evidence of a crime.â Officer Song determined there
was reasonable suspicion to conduct a search in accordance with the search
conditions of Youngâs supervised release. Meanwhile, Young failed to appear for
a mandatory random drug test.
On December 22, Young arrived at the probation office for a scheduled
visit. He was driven by his wife, Evans. Upon arrival, Young was handcuffed and
searched by Officer Song and other probation officers. No contraband was found
on his person. With Young temporarily detained, the probation officers went
outside to make contact with Evans. They searched the car and retrieved Youngâs
cellphone. Officer Song asked Evans if she was carrying a firearm. She stated
that she was and consented to a search of her purse. In the purse, a 9mm firearm
and a magazine were found.
After being informed that the probation officers would be conducting a
search of their home, Young and Evans agreed to let the probation officers drive
them back to the house. Young and Evans helped secure their dogs while the
probation officers conducted the search. About a dozen officers were present.
They searched the home for a period of several hours. The search team
uncovered a 4.7-gram bag of crack cocaine and a 3.4-gram bag of powdered
cocaine inside a childâs shoe in a childâs bedroom. They also found 35.9 grams
5
of marijuana in a kitchen drawer. In addition, they located a digital scale with
white residue and a partial box of 9mm ammunition.
Officer Johnson, acting as the evidence technician, conducted the search
of Youngâs phone and discovered some text messages relating to drug
transactions. On December 5, Young had offered to sell someone fifty âshinglesâ
for $1,000. In a text exchange on October 26, someone sent Young multiple
pictures of what appeared to be marijuana and asked, âYou need more or is them
good?!â Young responded, âOk I will let me send it out to some of my people.â
Because the quantities of drugs found were not typical of the weights that
warranted federal prosecution, the officers turned over the results of their search
of Youngâs home and cellphone to the Des Moines Police Department. Until then,
no state or local law enforcement personnel had been aware of the search.
A trial information was filed in the Polk County District Court charging
Young with possession with intent to deliver crack cocaine, possession of a
controlled substance (cocaine) as a second offense, possession of a controlled
substance (marijuana) as a second offense, and failure to possess a tax stamp.
See Iowa Code § 124.401(1)(c)(3), (5); id. § 453B.3.
Young moved to suppress the evidence found during the warrantless
search of his home, alleging violations of the Fourth Amendment to the United
States Constitution and article I, section 8 of the Iowa Constitution. A hearing
on the motion to suppress took place. Officers Johnson and Song testified.
The district court upheld the search on two grounds. First, it determined
that the âspecial needsâ exception authorized search under both the Fourth
Amendment and article I, section 8. See Griffin v. Wisconsin, 483 U.S. 868,
6
875â76 (1987); State v. Brooks, 888 N.W.2d 406, 416 (Iowa 2016); State v. King,
867 N.W.2d 106, 121â22 (Iowa 2015). Specifically, the court stated,
[H]ere, it was U.S. Probation Officers who conducted the search of
Defendantâs home in December of 2021, acting upon reasonable
suspicion Defendant had violated the terms of his probation and
then he missed a drug test. U.S. PO Johnson testified credibly that
the search was for the purposes of discovering evidence of violations
of probation rather than evidence of new criminal activity for new
criminal charges. Police from DMPD were called after the search.
(Citation omitted.)
Later, in denying Youngâs motion for reconsideration, the district court
provided an alternative ground for its ruling. It determined that even if Iowaâs
version of the special-needs exception did not justify the search under article I,
section 8, that was of no moment because the search was conducted entirely by
federal officers in compliance with federal standards. See State v. Ramirez,
895 N.W.2d 884, 898 (Iowa 2017). As the court put it, âDefendant was not under
state supervision nor did state officers or police officers conduct the search. As
such, the search was entirely justified in the federal justice system.â
A jury subsequently found Young guilty of three counts of possession of a
controlled substance second offense for the crack cocaine, cocaine, and
marijuana, respectively. It acquitted him of the more serious charge of
possession of crack cocaine with intent to deliver and acquitted him of failure to
possess a drug tax stamp. On March 21, 2023, the district court sentenced
Young to consecutive sentences of imprisonment totaling six years and ordered
him to pay fines and restitution. See Iowa Code § 124.401(5).
Young has appealed his convictions, arguing that the search of his home
violated article I, section 8. We retained the appeal.
7
III. Standard of Review.
âWe review the district courtâs denial of a motion to suppress based on
deprivation of a constitutional right de novo.â State v. Bauler, 8 N.W.3d 892, 897
(Iowa 2024) (quoting State v. Arrieta, 998 N.W.2d 617, 620 (Iowa 2023)). âWe
independently evaluate the entire record and consider the totality of the
circumstances.â Id. âWe defer to the findings of fact made by the district court,
âbut we are not bound by them.â â Id. (quoting Arrieta, 998 N.W.2d at 620).
IV. Analysis.
Young challenges the warrantless search of his home only as a violation of
article I, section 8 of the Iowa Constitution. We believe there is little room for
debate that the search complied with the Fourth Amendment, and Young does
not argue otherwise. We begin by reviewing relevant precedents of the United
States Supreme Court and our court.
A. The Fourth Amendment Special-Needs Doctrine. In Griffin v.
Wisconsin, the United States Supreme Court upheld a warrantless search of a
probationerâs apartment. 483 U.S. at 880. A probation officer performed the
search under a regulation that authorized any probation officer to search a
probationerâs apartment so long as the supervisor approved and there were
âreasonable groundsâ to believe contraband was present. Id. at 870â71. The
Court explained that â[a] Stateâs operation of a probation system, like its
operation of a school, government office or prison, or its supervision of a
regulated industry, likewise presents âspecial needsâ beyond normal law
enforcement that may justify departures from the usual warrant and
probable-cause requirements.â Id. at 873â74. Thus Griffin gave rise to the
so-called âspecial needsâ exception to the warrant requirement.
8
Going further, in United States v. Knights, the Court upheld the
warrantless search of a probationerâs apartment conducted by local law
enforcement rather than probation officers. 534 U.S. 112, 114â15, 122 (2001).
The Court recognized that the State has âa dual concern with a probationer.â
Id. at 120. Part of this concern involves âapprehending violators of the criminal
law.â Id. at 121. Citing statistics, the Court explained that â[t]he recidivism rate
of probationers is significantly higher than the general crime rate.â Id. at 120.
Therefore, the Court held that a warrantless search of a probationerâregardless
of its âofficial purposeââcould be squared with the Fourth Amendment so long
as it was based on reasonable suspicion and a probation agreement that
authorized warrantless searches at any time. Id. at 121â22.
B. The Special-Needs Doctrine Under Article I, Section 8. Our court
has not followed Knights in interpreting article I, section 8 of the Iowa
Constitution. In State v. Short, we held that a warrantless search of a
probationerâs apartment violated article I, section 8 despite a probation
agreement authorizing the search and even though law enforcement had âgood
reasonâ to conduct the search. 851 N.W.2d 474, 476â77, 502â04 (Iowa 2014).
Plymouth County sheriffâs deputies performed the search based on a warrant
that had the wrong address. Id. at 476. Thus, the search in Short âwas not a
probationary search but was instead an investigatory search by law enforcement
related to new crimes.â Id. at 476â77. In overturning the convictions, we
concluded that the warrant requirement has âfull applicabilityâ to home searches
of probationers by law enforcement. Id. at 506.
Subsequent to Short, we held in State v. King that article I, section 8 did
not necessarily bar a warrantless search by a parole officer of a paroleeâs home.
867 N.W.2d at 109. The parole search in King uncovered drugs used to prosecute
9
the defendant for a new crime. Id. We discussed the âspecial needsâ doctrine,
observing that Griffin was âthe most pertinent federal precedent in the
special-needs area for the present case.â Id. at 115. We noted that â[a] distinction
exists between searches to pursue the purposes of law enforcement and those to
pursue the purposes of carrying out the mission of parole.â Id. at 122. Applying
the special-needs doctrine, we held that the search was lawful. Id. at 126. We
concluded,
[P]arole officers have a special need to search the home of parolees
as authorized by a parole agreement and not refused by the parolee
when done to promote the goals of parole, divorced from the goals of
law enforcement, supported by reasonable suspicion based on
knowledge arising out of the supervision of parole.
Id. at 126.
A year later, in State v. Brooks, we followed a similar approach in a case
involving a probationer. 888 N.W.2d at 408. We decided that no violation of
article I, section 8 occurred when two Iowa probation officers made a warrantless
entry into a probationerâs bedroom. Id. The defendant had previously been
convicted of two methamphetamine-related offenses. Id. The probation officers
received a report that he had relapsed on methamphetamine. Id. The defendantâs
written probation agreement provided that he consented to warrantless searches
on reasonable suspicion and that he agreed not to possess or use drugs. Id.
We concluded that this probationary search, which yielded the
methamphetamine used to revoke the defendantâs probation, also fell within the
special-needs doctrine as elaborated in King. Id. at 410. The search was
performed by âprobation officers carrying out a probation mission.â Id. at 408.
As we put it, âThis is not a case like Short, where the probationary status of the
defendant became an after-the-fact justification for a warrantless search of his
residence for independent law-enforcement purposes.â Id. at 415.
10
C. The Silver Platter Doctrine in Iowa. Finally, a year after Brooks, we
relied on a separate legal doctrine to hold that a federal search should be
evaluated under federal, rather than Iowa, standards, even though the results of
the search had been used as evidence in an Iowa criminal case. That is, we found
no violation of Iowa law when federal agentsâhaving conducted a search of an
apartment pursuant to a form of search warrant that was valid under federal but
not Iowa lawâturned the contraband over to state authorities for prosecution.
See State v. Ramirez, 895 N.W.2d at 886â88.
The case of State v. Ramirez began when agents of the federal Department
of Homeland Security learned that the defendant in Waterloo was due to receive
a package from Mexico that contained methamphetamine. Id. at 886â87. They
obtained an anticipatory search warrant from the federal district court based on
the expected future delivery. Id. at 887. Federal law permits anticipatory search
warrants; Iowa law does not. Id. at 892â93; see also State v. Gillespie, 530 N.W.2d
446, 449 (Iowa 1995) (â[Iowa Code] sections 808.3 and 808.4 plainly do not
contemplate future acts or events as constituting probable cause.â). The federal
agents executed the warrant and seized the methamphetamine, but thereafter
the case was turned over to the Black Hawk County Attorneyâs office. Ramirez,
895 N.W.2d at 888.
In sustaining the search over the objection that it did not comply with Iowa
law, we reasoned,
When a bona fide federal investigation leads to a valid federal search,
but the evidence is later turned over to state authorities for a state
prosecution, we do not believe deterrence or judicial integrity
necessarily require a reexamination of the search under standards
11
that hypothetically would have prevailed if the search had been
performed by state authorities.
Id. at 898. We emphasized that
[t]he record is devoid of any suggestion that any party was trying to
circumvent Iowa search and seizure law. . . . It is true that the case
was ultimately turned over for state prosecution. But there is no
indication in the record that such a determination had been made
before the search warrant was obtained and the search was carried
out.
Id. at 893.
D. Resolving This Case. The State here argues that the federal probation
officersâ search of Youngâs home can be upheld on three independent grounds.
First, it urges that Ramirez applies to this case. In the Stateâs view, an Iowa court
should not exclude the results of a search performed by federal officers that was
indisputably valid under federal law, regardless of what Iowa law may provide if
the search were conducted by Iowa officers. Second, the State maintains that the
special-needs exception to the warrant requirement as recognized in King and
Brooks would apply here even if the search were measured according to Iowa
constitutional standards. Third, the State argues that Short should, if necessary,
be overruled and Knights should be adopted as the controlling law under article
I, section 8.
We reach only the Stateâs first argument, which is dispositive. This case is
like Ramirez in that the search was clearly lawful. Young asks us to evaluate it
as if it had been performed by someone else who didnât actually perform it. In
Ramirez, we asked, âShould Iowa invalidate a search that would not have been
invalidated under the law of the jurisdiction pursuant to which it was
conducted?â 895 N.W.2d at 894. We answered no. Id. We concluded that
admission of the evidence neither ârewarded unlawful police conduct or
undermined the integrity of our courtsâ; rather, âit accorded a proper recognition
12
to the bona fide actions of the federal government pursuant to that governmentâs
lawful authority.â Id. at 898. All that is true here.
Also, as in Ramirez, there is no âdirty silver platter.â See id. at 893;
Wayne A. Logan, Dirty Silver Platters: The Enduring Challenge of
Intergovernmental Investigative Illegality, 99 Iowa L. Rev. 293, 312â13 (2013).
This was purely the activity of a federal probation office dealing with someone
who was on federal supervised release. State and local law enforcement did not
know of the operation. So no suggestion can be made that this was an attempt
to bypass Iowa search and seizure restrictions by enlisting federal officers.
Further, in Ramirez, we noted that the weight of out-of-state authority
supported our decision to admit the results of a federal search that was lawful
by federal standards:
Courts in a number of states have concluded that evidence
lawfully obtained by federal officials, under a federal investigation
meeting federal standards, may be used in a subsequent state
prosecution even though state law would not have permitted the
same type of search. See Morales v. State, 407 So. 2d 321, 329
(Fla. Dist. Ct. App. 1981); People v. Fidler, 72 Ill.App.3d 924,
29 Ill.Dec. 51, 391 N.E.2d 210, 211 (1979); Basham v.
Commonwealth, 675 S.W.2d 376, 379 (Ky. 1984); Commonwealth v.
Brown, 456 Mass. 708, 925 N.E.2d 845, 849â51 (2010); State v.
Mollica, 114 N.J. 329, 554 A.2d 1315, 1327â28 (1989); State v.
Toone, 823 S.W.2d 744, 747 (Texas Ct. App. 1992); King v. State,
746 S.W.2d 515, 519 (Tex. Ct. App. 1988); State v. Coburn, 165 Vt.
318, 683 A.2d 1343, 1347 (1996); State v. Dreibelbis, 147 Vt. 98,
511 A.2d 307, 308 (1986); State v. Bradley, 105 Wash.2d 898,
719 P.2d 546, 549 (1986) (en banc); State v. Gwinner, 59 Wash. App.
119, 796 P.2d 728, 731â32 (1990); see also People v. Blair, 25 Cal.3d
640, 159 Cal. Rptr. 818, 602 P.2d 738, 747â48 (1979) (en banc)
(finding evidence admissible that had âbeen legally seized under
federal law and under the law of Pennsylvania, [even though] the
seizure would have violated article I, section 13, of the California
Constitution if it had occurred in this stateâ).
895 N.W.2d at 895. Several of the cases cited involved searches that would have
violated the stateâs constitution if performed by state officials. See Commonwealth
13
v. Brown, 925 N.E.2d 845, 851 (Mass. 2010); State v. Toone, 823 S.W.2d 744,
748 (Tex. App. 1992); State v. Gwinner, 796 P.2d 728, 729 (Wash. App. 1990);
State v. Mollica, 554 A.2d 1315, 1323 (N.J. 1989); People v. Blair, 602 P.2d 738,
747â48 (Cal. 1979) (en banc). We discussed two of themâState v. Mollica and
Commonwealth v. Brownâat length approvingly. See Ramirez, 895 N.W.2d at
895â98.
Young points out that we were careful to emphasize in Ramirez that the
defendant was claiming only a violation of the Iowa warrant statute; he did not
claim a violation of the Iowa Constitution. See id. at 898 (âWhile Iowa law would
not have authorized the type of warrant issued, no argument is raised that the
searchâif statutorily authorizedâwould have violated the Iowa Constitution.â).
Indeed, we distinguished some adverse out-of-state authority on that basis:
It is true that a few state jurisdictions have declined to allow
evidence seized in a warrantless federal search to be admitted in a
state proceeding where the search would have violated the state
constitution. See State v. Torres, 125 Hawaiâi 382, 262 P.3d 1006,
1021 (2011); State v. Cardenas-Alvarez, 130 N.M. 386, 25 P.3d 225,
233 (2001); People v. Griminger, 71 N.Y.2d 635, 529 N.Y.S.2d 55,
524 N.E.2d 409, 412 (1988). Yet the present case is different.
Although Ramirez raises article I, section 8 of the Iowa Constitution
in his briefing, he does not claim that the search itself would have
violated the Iowa Constitution. Rather, he maintains only that Iowa
statutes do not authorize this type of search and, therefore, it would
violate the Iowa Constitution to admit the results of the search in an
Iowa court. We disagree with that broad proposition.
Id.
But we agree with the State that the underlying rationale of Ramirez does
not turn on whether the federal search was alleged to violate Iowa statutory or
Iowa constitutional standards. The critical point in Ramirez was that âthe search
was lawful under federal law.â Id. at 894. We said that the out-of-state decisions
upholding such searches were âpersuasive,â notwithstanding that several of
14
them involved searches that would have violated state constitutions. Id. at 898.
And we focused on the twin goals of deterrence and judicial integrity, neither of
which would be impaired so long as the search was lawful according to the
standards by which it was conducted. Id.2
Young urges us to follow the Hawaii Supreme Courtâs decision in State v.
Torres, 262 P.3d 1006 (Haw. 2011). There the court adopted a rule against the
admittance in Hawaii courts of evidence obtained by federal agents under a
search that complied with the Fourth Amendment but would have violated the
Hawaii Constitution. Id. at 1019â21. The decision was in a sense advisory
because the searches in the case were ultimately upheld. Id. at 1023â24.
In any event, we respectfully disagree with the Hawaii Supreme Courtâs
reasoning. We do not believe that by admitting the results of a lawful federal
search, state courts âwould necessarily be placing their imprimatur of approval
on evidence that would otherwise be deemed illegal, thus compromising the
integrity of our courts.â Id. at 1019. By that logic, when courts apply the
âinevitable discoveryâ doctrine, under which illegally obtained evidence can be
admitted when it would have been discovered anyway, see, e.g., State v. Tyler,
867 N.W.2d 136, 171 (Iowa 2015), they are likewise giving an imprimatur to an
improper search. We think not. A court decision stands for what it says, not for
what it might symbolize. Nor do we agree that exclusion of the evidence is
necessary to âdeter any federal and state cooperation âto evade state law.â â
Torres, 262 P.3d at 1020. That goal can be achieved simply by suppressing the
2One can conceive of an extreme case where evidence was obtained in a jurisdiction whose
legal system did not offer basic human rights protections. We might say that our judicial integrity
would be offended by using that evidence in one of our criminal cases. Obviously, thatâs not the
situation here.
15
evidence when the record shows that there was cooperation aimed at evading
state law.
We are also aware that during the intervening time period since Ramirez
was decided, the Vermont Supreme Court declined to allow âsilver platterâ
evidence in State v. Walker-Brazie, 280 A.3d 24, 25â26 (Vt. 2021). That 3â2
decision involved a warrantless stop and search of a vehicle near the Canadian
border by federal Border Patrol agents using their âroving patrolâ authority. Id.
at 26; see also United States v. Brignoni-Ponce, 422 U.S. 873, 878â85 (1975).
Controlled substances were found, and the case was turned over to Vermont
authorities for prosecution. Walker-Brazie, 280 A.3d at 26. The court noted, âA
warrantless search of an automobile is per se unreasonable under Article 11 [of
the Vermont Constitution] unless there exists probable cause and a showing of
exigent circumstances, meaning a threat to officer safety or to the preservation
of evidence.â Id. at 29. The court also noted, âThe language of Article 11 is broadly
wordedâit protects individuals from unreasonable searches or seizures âby any
officer or messenger.â â Id. at 36. Additionally, the court emphasized the âprivacy
rationaleâ behind Vermontâs exclusionary rule. Id. at 35â37. For these reasons
and others, the court held that âevidence gathered in violation of article 11 by
Border Patrol agents on roving patrol is not admissible in a state criminal
proceeding.â Id. at 37.
Walker-Brazie is animated by an approach different from the one we have
taken in our constitutional jurisprudence. Article I, section 8âunlike article 11
of the Vermont Constitutionâdoes not purport to apply to âany officer.â Compare
Iowa Const. art. I, § 8, with Vt. Const. ch. I, art. XI. Thus, we have evaluated the
legality of a search conducted entirely by non-Iowa officials according to the
standards of that other jurisdiction. See Ramirez, 895 N.W.2d at 898.
16
Additionally, we have not said that our exclusionary rule exists to protect privacy
per se. Rather, our exclusionary rule serves to remedy constitutional violations.
See State v. Cline, 617 N.W.2d 277, 289 (Iowa 2000) (en banc), abrogated on other
grounds by State v. Turner, 630 N.W.2d 601, 606 n.2 (Iowa 2001). Federal
probation officers committed no constitutional violation at the moment they
searched Youngâs home under federal authority; Young concedes this point.
In sum, we conclude that the reasoning and result in Ramirez extend to a
search by federal probation officers that occurred without the knowledge or
involvement of state law enforcement and that complied with federal law but that
is alleged to contravene state constitutional standards. The district courtâs ruling
âaccorded a proper recognition to the bona fide actions of the federal government
pursuant to that governmentâs lawful authority.â Ramirez, 895 N.W.2d at 898.
We hold that the motion to suppress was properly denied.
V. Conclusion.
For the foregoing reasons, we affirm Youngâs convictions and sentence.
Affirmed.
Case Information
- Court
- Iowa
- Decision Date
- December 20, 2024
- Status
- Precedential