State Of Iowa Vs. Jordan Heath Dentler

Citation: Not availableDocket: 122 / 06-1905

Court: Supreme Court of Iowa; December 6, 2007; Iowa; State Supreme Court

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The Supreme Court of Iowa, in case No. 122. 06-1905, filed on December 7, 2007, addresses the appeal by the State of Iowa challenging a district court order that suppressed evidence obtained after the arrest of Jordan Heath Dentler. The district court found that Iowa law enforcement officers violated Missouri’s Fresh Pursuit Statute by failing to present Dentler to a Missouri magistrate before returning him directly to Iowa. 

The facts indicate that Dentler was pursued by Iowa Deputy Charles Henderson for reckless driving, which continued into Missouri. Upon apprehension, an open beer can was discovered in the vehicle, and officers observed signs of intoxication, including a strong smell of alcohol on Dentler's breath. Despite a lack of clarity on jurisdictional procedures between the Iowa and Missouri officers, Dentler was arrested and later tested for sobriety in Iowa.

The Supreme Court determined that the district court erred in applying the exclusionary rule to the evidence obtained after Dentler's removal from Missouri, ultimately reversing the district court's decision. The court indicated that the evidence of alcohol intoxication should not be excluded from the criminal proceedings against Dentler, allowing the charges to proceed, including operating a motor vehicle while intoxicated, second offense.

Iowa law lacks precedent regarding the application of the exclusionary rule in cases where a defendant is not presented to a magistrate following an arrest by out-of-state officers. The district court, drawing on the Pennsylvania case Commonwealth v. Sadvari, found it persuasive that the exclusionary rule should apply when there is a violation of the magistrate provision under a fresh pursuit statute, as it serves state interests and ensures compliance with legal procedures. Consequently, the court granted a motion to suppress evidence obtained after the arrest.

The case at hand involves determining whether evidence obtained by Iowa officials after Dentler's arrest in Missouri should be excluded due to the failure to present him to a Missouri magistrate. While some jurisdictions have applied the exclusionary rule in similar situations (e.g., Sadvari and People v. Jacobs), others, like State v. Ferrell, have ruled against it, emphasizing that failure to present a defendant does not invalidate the arrest or necessitate evidence exclusion. The Iowa court has historically applied the exclusionary rule primarily in cases of constitutional violations or specific statutory mandates requiring exclusion. The court’s commitment to the rule is evident in its refusal to allow a good faith exception for violations of the Iowa Constitution and its focus on upholding fundamental rights and deterring police misconduct.

Limiting the statutory application of the exclusionary rule to instances where the legislature has explicitly mandated exclusion reflects legislative intent. However, the scope of the exclusionary rule has expanded to include statutory violations affecting fundamental rights with constitutional implications, even when not explicitly stated by the legislature. Relevant cases include *State v. Moorehead*, which applied the rule to violations of the right to contact family upon arrest, and *State v. Buenaventura*, which did not apply the rule to Vienna Convention violations lacking fundamental rights implications. The rule has also been applied in cases of police misconduct, as seen in *Kjos*, where a breath test was excluded due to police coercion.

In the case at hand, Dentler argues that the exclusionary rule should apply due to a due process violation from deputies failing to present him to a Missouri magistrate as required by the Fresh Pursuit Statute. He contends that such a presentation would have led to his release for lack of probable cause. However, the court finds that the deputies had sufficient grounds for probable cause based on Dentler's erratic driving, alcohol consumption, and evidence found at the scene. Dentler was subsequently presented to an Iowa judge, allowing him to challenge the legality of his arrest, thus negating the claim of a due process violation. The court concludes that the real issue is whether the violation of Missouri law warrants exclusion of evidence, noting that the Missouri statute does not explicitly require such exclusion. The Iowa law requires examination of whether the statute specifically mandates evidence exclusion, and the lack of explicit language in the Missouri statute leads to the conclusion that the exclusionary rule does not apply in this instance.

The statute in question does not involve a fundamental right of the defendant as it pertains to the exclusionary rule, which requires that a right must be rooted in fundamental fairness to the accused. The magistrate provision in Missouri’s Fresh Pursuit Statute is primarily aimed at upholding the state's sovereign rights, not at protecting individual defendants from evidence-gathering overreach. Consequently, statutory violations minimally related to evidence collection do not typically trigger the exclusionary rule.

The defendant, Dentler, cannot vicariously claim rights of the State of Missouri, and it is noted that Missouri officers at the scene did not object to the actions taken by Iowa authorities, which weakens the argument for applying the exclusionary rule. Dentler's assertion that a Missouri magistrate would have prevented his arrest due to a lack of probable cause is rejected.

Additionally, there is no evidence of police misconduct or deliberate misrepresentation of law to procure evidence. Concerns about insufficient deterrence for future violations do not warrant expanding the application of the exclusionary rule, especially since the potential benefits of violating the magistrate provision are minimal. The court reserves the right to address future violations if they become a recurrent issue. The district court's suppression order is reversed, and the case is remanded for further proceedings.