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Case No. 18-2171

State of Iowa
v.
Joseph Jackson Howard

Appellee

State of Iowa

Appellant

Joseph Jackson Howard

Attorney for the Appellee

Kyle Hanson and Tyler J. Buller, Assistant Attorneys General

Attorneys for the Appellant

Ryan J. Ellis
Cathleen J. Siebrecht

Court of Appeals

Court of Appeals Opinion

Opinion Number:
18-2171
Date Published:
Jan 23, 2020
Summary

            Appeal from the Iowa District Court for Warren County, Mark F. Schlenker, District Associate Judge.  AFFIRMED.  Considered by Tabor, P.J., May, J., and Scott, S.J.  Opinion by Scott, S.J.  (8 pages)

            Joseph Howard appeals his conviction of possession of a controlled substance.  He challenges the district court’s denial of his motion to suppress evidence obtained as a result of a traffic stop, arguing the traffic stop lacked probable cause and was therefore unconstitutional.  OPINION HOLDS: We agree with the district court that law enforcement had probable cause to believe the headlamp on the vehicle Howard was driving was inadequate under Iowa law.  At the very least, reasonable suspicion justified the stop.  We affirm the denial of Howard’s motion to suppress and his ensuing conviction.

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