State of Iowa, Appellee v. Christine Ann Kern, Appellant

Summary

The court held that the warrantless search of Kern's home violated article I, section 8 of the Iowa Constitution because her parole agreement did not establish consent and no recognized exception to the warrant requirement applied. The court also held that sufficient evidence supported Kern's conspiracy conviction but not her convictions for possession, manufacturing, or failure to affix a drug tax stamp. The judgment was reversed, the three unsupported convictions were dismissed, and the case was remanded for a new trial limited to conspiracy. Mansfield, J., joined by Waterman, J., concurred in the sufficiency analysis but would have upheld the search and disagreed with the majority's treatment of special needs and reasonable suspicion.