(Before I go further, a mild disclaimer: I'm going to be talking- or typing at least tangentially about my day job. Which doesn't happen on the blog all that often, so buckle up.)
So, let's talk about the Coleman decision, shall we?
Basically, an officer was checking plates for stolen vehicles and ran a plate belonging to a person who he knew had a suspended license. It was dark, so he couldn't tell who was driving the car, so he pulled it over. Instead of the female registered owner with a suspended license, he found a male subject who advised he borrowed the car from his sister and produced an Iowa ID. Officer ran it, found out said subject was barred and he was arrested.
Mr. Coleman (the male subject in question) appealed his conviction and found no joy in two lower courts before the State Supreme Court, in a 4-3 decision saying:
"when the reason for a traffic stop is resolved and there is no other basis for reasonable suspicion, article 1, section 8 of the Iowa Constitution requires that the driver must be allowed to go his or her way without further ado."Wait, What?
So if I'm getting this right. (Which, as I mentioned above, is a questionable assertion on my part.) The officer had probable cause to pull the car over because he was checking for the registered owner who was suspended. When he didn't find the registered owner, that (according to the State Supreme Court) should have been the end of that. Probable cause done. Traffic stop over.
For my sins, I slogged through this decision. Twice. And there's a lot I don't understand- the whole issue of issue preservation and error preservation seems to be a bridge too far with the legalese. (The dissent seems willing to dismiss Coleman's claim solely on this basis- he didn't ask for protections under the state constitution in his original claim, so why are the majority giving it to him?) It seems like a reasonable point to make, except neither Wikipedia nor Mr. Google seemed to be able to give me a simple dictionary definition on what the hell both the majority or the dissent seem to be getting at with the whole discussion... so I did what normal people do when confronted with technobabble and jargon they don't understand. I smiled, I nodded and I kept reading.
Color me surprised: I had no idea that traffic stops were so complicated from a legal point of view- I counted twenty-three cases cited by the majority in their argument. From my point of view, they're pretty ubiquitous. (I don't want to say 'routine' because from an officer's point of view, there's no such thing as a routine traffic stop.) Given the blizzard of case law they assembled, you're left the impression that a decision like this was coming- Mr. Coleman's case just happened to be Iowa's turn on this particular carousel.
Then, you get to the dissent. The dissent comes across as the more focused argument in many ways- sticking with the Rodriguez case cited from the Supreme Court and the Jackson case from the Iowa State Supreme Court. The resulting argument is cleaner and much less convoluted. If it were possible for me to view this from a purely objective position, free from any internal biases I might have, I could see the logic in what the dissenters are saying.
It's the intricacies of what makes this fascinating to read. No one is objecting to the stop- despite the majority's suggestion of racial profiling, no one is asserting that race played a part in the stop- except obliquely. At issue is whether or not asking for identification after the original reason for the stop has been resolved constitutes an unlawful extension of the stop and therefore a 4th Amendment violation. (I think?) You get the idea though- we're getting right down into the nitty gritty of this traffic stop. My original thought about all this was that if the impetus for the officer's actions was checking for stolen vehicles/wanted people by running plates, then surely upon finding someone who is not the registered owner behind the wheel, it would be reasonable for him to verify that person's identity. But that original impetus of the officer's actions has no bearing on the probable cause for the stop- so that was the end of my Matlock impression.
Given the fact that cases are cited in the decision that plainly show that states have a compelling interest in maintaining safe highways combined with the fact that the dissent points out that Iowa Code requires motorists to have a valid license and produce it upon demand of a peace officer makes this decision something of a head-scratcher. Plus, it raises all kind of safety issues. So if an officer makes a stop to check for a registered owner and find someone not the registered owner behind the wheel, then oh well. Bye now!
There's a lot about this I don't get- and I didn't hear anything about an appeal, which I'm guessing will probably happen at some point. In the meantime, I'm going to file this post under: "I Should Have Gone To Law School" and wait for the next interesting decision to be handed down.