reasonable grounds test in Iowa

2019See Westinghouse Credit Corp. v. Crotts, 98 N.W.2d 843, 848 (Iowa 1959) (finding statements in the opinion that were “not necessary to a determination of the case” are considered “mere dicta and not authority to be followed”). 7 prudent person’s belief that an offense has been committed.” State v. Braun, 495 N.W.2d 735 , 738–39 (Iowa 1993); see also State v. Boleyn, 547 N.W.2d 202, 205 (Iowa 1996) (“The reasonable grounds test is determined under the facts and circumstances known to the officers at the time the implied consent law is evoked.”).

2001(Emphasis added.) See also State v. Boleyn, 547 N.W.2d 202, 205 (Iowa 1996) (“The reasonable grounds test is determined under the facts and circumstances known to the officers at the time the implied consent law is invoked.”); Munson v. Iowa Dep’t of Transp., 513 N.W.2d 722, 725 (Iowa 1994) (“The reasonable grounds test is met ‘when the facts and circumstances known to the officer at the time action was required would have warranted a prudent person’s belief that an offense has been committed.’ ”) (Emphasis added) (quoting State v. Braun, 495 N.W.2d 735, 738 (Iowa 1993)).

2019See Westinghouse Credit Corp. v. Crotts, 98 N.W.2d 843, 848 (Iowa 1959) (finding statements in the opinion that were “not necessary to a determination of the case” are considered “mere dicta and not authority to be followed”). 7 prudent person’s belief that an offense has been committed.” State v. Braun, 495 N.W.2d 735 , 738–39 (Iowa 1993); see also State v. Boleyn, 547 N.W.2d 202, 205 (Iowa 1996) (“The reasonable grounds test is determined under the facts and circumstances known to the officers at the time the implied consent law is evoked.”).

2014Iowa Code section 804.7(3) permits an officer to make a warrantless arrest for an indictable offense such as OWI if the officer has “reasonable ground for believing that an indictable public offense has been committed and has reasonable ground for believing that the person to be arrested has committed it.” Cf. State v. Boleyn, 547 N.W.2d 202, 205 (Iowa 1996) (noting definition of “operate” is the immediate, actual physical control over a motor vehicle that has its engine running and that the reasonable grounds test is determined under facts and circumstances known to the officers at the time t

2014“The reasonable grounds test is met when the facts and circumstances known to the officer at the time action was required would have warranted a prudent person’s belief that an offense had been committed.” State v. Owens, 418 N.W.2d 340, 342 (Iowa 1988).

1994The reasonable grounds test is met “when the facts and circumstances known to the officer at the time action was required would have warranted a prudent person’s belief that an offense had been committed.” State v. Braun, 495 N.W.2d 735, 738-39 (Iowa 1993); State v. Owens, 418 N.W.2d 340, 342 (Iowa 1988).

1999Those procedures require that the circumstances show “reasonable grounds to believe that the person [sought to be tested] had been operating a motor vehicle in violation of section 321J.2 [the statute rendering it a crime to drive under the influence].” Iowa Code § 321 J.12(l); see Westendorf v. Iowa Dep’t of Transp., 400 N.W.2d 553, 555 (Iowa 1987) (interpreting the reasonable-grounds standard of section 321J.12 as previously numbered).

1993Iowa Code § 321J.5; cf. Westendorf v. Iowa Dep’t of Transp., 400 N.W.2d 553, 555 (Iowa 1987) (results of a preliminary breath screening test may be included in the determination of whether the reasonable grounds requirement under section 321J.12 (1985) is met to allow the department of transportation to revoke a person’s motor vehicle license).

2019See Westinghouse Credit Corp. v. Crotts, 98 N.W.2d 843, 848 (Iowa 1959) (finding statements in the opinion that were “not necessary to a determination of the case” are considered “mere dicta and not authority to be followed”). 7 prudent person’s belief that an offense has been committed.” State v. Braun, 495 N.W.2d 735 , 738–39 (Iowa 1993); see also State v. Boleyn, 547 N.W.2d 202, 205 (Iowa 1996) (“The reasonable grounds test is determined under the facts and circumstances known to the officers at the time the implied consent law is evoked.”).

2019See Westinghouse Credit Corp. v. Crotts, 98 N.W.2d 843, 848 (Iowa 1959) (finding statements in the opinion that were “not necessary to a determination of the case” are considered “mere dicta and not authority to be followed”). 7 prudent person’s belief that an offense has been committed.” State v. Braun, 495 N.W.2d 735 , 738–39 (Iowa 1993); see also State v. Boleyn, 547 N.W.2d 202, 205 (Iowa 1996) (“The reasonable grounds test is determined under the facts and circumstances known to the officers at the time the implied consent law is evoked.”).

2014The “reasonable ground for belief” standard is “tantamount to probable 5 cause.” Cf. State v. Freeman, 705 N.W.2d 293, 298 (Iowa 2005) (discussing “totality of circumstances” test for Iowa Code section 804.7).

2001(Emphasis added.) See also State v. Boleyn, 547 N.W.2d 202, 205 (Iowa 1996) (“The reasonable grounds test is determined under the facts and circumstances known to the officers at the time the implied consent law is invoked.”); Munson v. Iowa Dep’t of Transp., 513 N.W.2d 722, 725 (Iowa 1994) (“The reasonable grounds test is met ‘when the facts and circumstances known to the officer at the time action was required would have warranted a prudent person’s belief that an offense has been committed.’ ”) (Emphasis added) (quoting State v. Braun, 495 N.W.2d 735, 738 (Iowa 1993)).