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Case No. 19-1857

State of Iowa
v.
Khalen Richard Price Williams

Khalen Williams appeals from the judgment of sentence for felon in possession of a firearm in violation of Iowa Code section 724.26. He challenges the district court’s denial of his motion to suppress evidence. Particularly, he argues law enforcement officers lacked reasonable suspicion of criminal activity, or that he was armed and dangerous, and unlawfully removed him from the backseat of a Lyft vehicle and patted him down in violation of his rights under article I, section 8 of the Iowa Constitution. He further argues the officers questioned him about possession of a firearm without warning him of his right against self-incrimination.

County:
Polk

Resister

State of Iowa

Applicant

Khalen Richard Price Williams

Attorneys for Resister

Sharon K. Hall

Attorneys for Applicant

Theresa R. Wilson

Supreme Court

Oral Argument Schedule

15-15-5

Sep 23, 2021 7:00 PM George Daily Auditorium, Oskaloosa High School, 1800 N. 3rd Street, #2, Oskaloosa, IA

Briefs

Court of Appeals

Court of Appeals Opinion

Opinion Number:
19-1857
Date Published:
Dec 16, 2020
Summary

            Appeal from the Iowa District Court for Polk County, Lawrence P. McLellan, Judge.  AFFIRMED.  Heard by Bower, C.J., and Vaitheswaran and Greer, JJ.  Opinion by Greer, J.  (10 pages)

            As a rear-seat passenger in a Lyft vehicle whose driver was pulled over for traffic violations, Khalen Williams challenges the police officers’ actions leading to a warrantless search that resulted in his criminal conviction.  Williams appeals, arguing that the court erred in denying his motion to suppress evidence obtained during the warrantless search and seizure of his person.  Williams raises three arguments: (1) the officers lacked reasonable suspicion to conduct a pat down search of his person for weapons; (2) his admission to possessing a firearm was a product of custodial interrogation without the benefit of Miranda warnings and should have been suppressed; and (3) we should decline to follow Maryland v. Wilson, 519 U.S. 408, 415 (1997), which holds that “an officer making a traffic stop may order passengers to get out of the car pending completion of the stop,” under the Iowa Constitution.  OPINION HOLDS: Because Williams did not advocate for a different standard under the Iowa Constitution in his motion to suppress to the district court, his claim that the Iowa Constitution requires more protection for passengers than the Federal Constitution is not preserved.  Additionally, because we find the officers involved had reasonable suspicion that Williams was potentially armed and dangerous—even without Williams’s statements admitting he had a gun—we find the officers had reasonable suspicion to support the pat down of Williams for weapons.  We affirm the district court’s denial of Williams’s motion to suppress. 

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