State of Iowa, Appellee v. Scottize Danyelle Brown, Appellant.

Summary

The court held that a traffic stop is constitutionally valid under both the Fourth Amendment and article I, section 8 of the Iowa Constitution when the officer has objectively reasonable grounds to believe a traffic violation occurred, regardless of the officer's subjective investigative motivation. Because the officer observed Brown accelerate through a red light, probable cause supported the stop, and trial counsel was not ineffective for failing to make a meritless probable-cause challenge. Chief Justice Cady and Justice Appel, dissenting, would have prohibited pretextual stops motivated by race or other impermissible considerations despite an objectively valid traffic violation.