State of Iowa
v.
Prince G. Paye
Defendant appealed the judgment and sentence entered on his conviction for driving while barred following a bench trial on stipulated evidence. Defendant contended the district court should have granted his motion to suppress and erred by finding a trailer ball partially obscuring the registration plate on his vehicle constituted a violation of Iowa Code section 321.38 (2019) and gave the arresting officer probable cause to make a traffic stop. The court of appeals reversed and remanded. The State seeks further review.
Applicant
State of Iowa
Resister
Prince G. Paye
Attorney for the Applicant
Aaron Rogers
Attorney for the Resister
Melinda J. Nye
Supreme Court
Oral Argument Schedule
Non-Oral
Oct 13, 2022 9:00 AM
Briefs
Supreme Court Opinion
Opinion Number:
Date Published:
Court of Appeals
Court of Appeals Opinion
Opinion Number:
Date Published:
Summary
Appeal from the Iowa District Court for Polk County, Kevin Parker, District Associate Judge. REVERSED AND REMANDED. Heard by Tabor, P.J., May, J., and Danilson, S.J. Opinion by Tabor, P.J. Dissent by May, J. (22 pages)
Police detained Prince Paye because a ball hitch partially blocked the view of a single letter of the car’s license plate. On appeal, he argues the traffic stop was unjustified. OPINION HOLDS: Section 321.38 is ambiguous. But relying on canons of interpretation and the rule of lenity, we hold Paye did not violate its requirements. Because the stop was based on a mistake of law, all evidence stemming from it must be suppressed. We reverse and remand. DISSENT ASSERTS: Based on the statutory language, our court’s prior decisions, and especially the supreme court’s teachings in State v.Harrison, 846 N.W.2d 362 (Iowa 2014), I conclude Iowa Code section 321.38 (2019) required Prince Paye to place his license plate so that the entire registration plate number would be “clearly visible.” Because part of Paye's registration plate number was hidden behind a trailer ball, Paye violated this requirement. So the officer was justified in stopping Paye, the motion to suppress was properly denied, and Paye’s conviction should be affirmed. I respectfully dissent.