Iowan seeks to limit a Fourth Amendment exception in appeal to U.S. Supreme Court

by Rox Laird | November 28, 2018

The U.S. Supreme Court on Friday will consider whether it will hear an appeal from an Iowa man who argues his drunk-driving conviction was the product of an unconstitutional search and seizure.

The appeal focuses on the reach of what’s known as a “community caretaking” exception to the Fourth Amendment in situations where, as in Coffman’s case, a law-enforcement officer stops to assist a motorist. The exception allows a warrantless seizure based on an officer’s reasonable belief that an emergency exists or an individual needs assistance.

Coffman’s drunk-driving arrest occurred after a Story County deputy sheriff pulled behind Coffman’s vehicle stopped on the shoulder of a rural highway in the early morning hours. The officer switched on his flashing lights, approached the vehicle to see if the occupants needed assistance and initiated the arrest after smelling alcohol in the car.

Coffman argued that the deputy had no grounds to initiate the traffic stop because there was no evidence that he needed assistance.

The Iowa Supreme Court, in a 4-2 decision handed down June 22, held that the community-caretaking exception applied to Coffman’s arrest. The decision was written by Justice Edward Mansfield and joined by Chief Justice Mark Cady and Justices Bruce Zager and Thomas Waterman. Justice Brent Appel, joined by Justice David Wiggins, dissented. Justice Daryl Hecht took no part in the case.

In his appeal of that decision to the U.S. Supreme Court, Coffman urges the Court to rule that community caretaking is not a stand-alone exception to the Fourth Amendment and must be applied only under narrowly defined circumstances.

The justices are scheduled to consider Coffman’s appeal at their conference Friday and they are expected to announce next week whether it will be heard.


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February 2024 Opinion Roundup

The Iowa Supreme Court entered opinions in eighteen cases during February 2024. You can read Rox Laird’s analysis of Singh v. McDermott, Selden v. DMACC, and Senator Roby Smith et al. v. Iowa District Court for Polk County. The remaining opinions from February are summarized here.


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