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:
Date Published:
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.