Iowa Search & Seizure: Inventory Search: Closed Container

Iowa case law summary by Attorney Richard Clem: Iowa Search & Seizure: Inventory Search: Closed Container.

State of Iowa v. Bion Blake Ingram. Iowa Search & Seizure: Inventory Search: Closed ContainerC

The Iowa Supreme Court held that the search and seizure protections of Article I, Section 8 of the Iowa Constitution were greater than those under the Fourth Amendment of the U.S. Constitution. Under Iowa law, a closed container located in an impounded vehicle may not be opened by police solely for the purpose of inventorying the contents, absent consent by the owner or operator.

The Supreme Court reversed the conviction of the defendant, who had been convicted in Jasper County.

No. 16-0736 (Iowa June 29, 2018).

Please see the original opinion for the court's exact language.


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Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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