Terry-type stop (Iowa) · Go Syfert
← Iowa issues

Terry-type stop in Iowa

10 Iowa opinions name it 2 courts 2011–2025 3 in the last five years

The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
United States v. Edward Clark Jr.green
cadc · 1994 · cited in 3 Iowa opinions naming this issue, 2017–2017
2 sentences

2017United States v. Clark, 24 F.3d 299, 303 (D.C.

2017United States v. Clark, 24 F.3d 299, 303 (D.C.

33
State v. Clinegreen
iowa · 2000 · cited in 2 Iowa opinions naming this issue, 2019–2019
2 sentences

2019See id.

2019See id.

22
Virginia v. Mooregreen
scotus · 2008 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025We do not inquire into the officers’ reasons for conducting the search of the arrestee’s person because “[t]he interests justifying search are present whenever an officer makes an arrest.” Virginia v. Moore, 553 U.S. 164, 177 (2008); see also Robinson, 414 U.S. at 234–35 (explaining that the close contact with suspects when making an arrest and transporting them to the jail, as opposed to the “fleeting contact” involved with “Terry-type stop[s,] . . . is an adequate basis for treating all custodial arrests alike for purposes of search justification”); Byrd, 310 P.3d at 796 (“[S]earches of the

11
State v. Byrdgreen
wash · 2013 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025We do not inquire into the officers’ reasons for conducting the search of the arrestee’s person because “[t]he interests justifying search are present whenever an officer makes an arrest.” Virginia v. Moore, 553 U.S. 164, 177 (2008); see also Robinson, 414 U.S. at 234–35 (explaining that the close contact with suspects when making an arrest and transporting them to the jail, as opposed to the “fleeting contact” involved with “Terry-type stop[s,] . . . is an adequate basis for treating all custodial arrests alike for purposes of search justification”); Byrd, 310 P.3d at 796 (“[S]earches of the

11
United States v. Robinsongreen
scotus · 1973 · cited in 1 Iowa opinions naming this issue, 2025–2025
2 sentences

2025We do not inquire into the officers’ reasons for conducting the search of the arrestee’s person because “[t]he interests justifying search are present whenever an officer makes an arrest.” Virginia v. Moore, 553 U.S. 164, 177 (2008); see also Robinson, 414 U.S. at 234–35 (explaining that the close contact with suspects when making an arrest and transporting them to the jail, as opposed to the “fleeting contact” involved with “Terry-type stop[s,] . . . is an adequate basis for treating all custodial arrests alike for purposes of search justification”); Byrd, 310 P.3d at 796 (“[S]earches of the

2025We do not inquire into the officers’ reasons for conducting the search of the arrestee’s person because “[t]he interests justifying search are present whenever an officer makes an arrest.” Virginia v. Moore, 553 U.S. 164, 177 (2008); see also Robinson, 414 U.S. at 234–35 (explaining that the close contact with suspects when making an arrest and transporting them to the jail, as opposed to the “fleeting contact” involved with “Terry-type stop[s,] . . . is an adequate basis for treating all custodial arrests alike for purposes of search justification”); Byrd, 310 P.3d at 796 (“[S]earches of the

11
State of Iowa v. Randall Lee Palsgreen
iowa · 2011 · cited in 1 Iowa opinions naming this issue, 2017–2017
1 sentence

2017As a result, the federal courts and many state courts have sought to 10 apply Terry principles in evaluating searches and seizures arising from traffic stops.” State v. Pals, 805 N.W.2d 767, 775 (Iowa 2011).

11
Berkemer v. McCartygreen
scotus · 1984 · cited in 1 Iowa opinions naming this issue, 2011–2011
2 sentences

2011In Berkemer v. McCarty, 468 U.S. 420, 439 , 104 S.Ct. 3138, 3150 , 82 L.Ed.2d 317, 334 (1984), the Supreme Court concluded that a traffic stop was more analogous to a Terry-type stop than a formal arrest.

2011In Berkemer v. McCarty, 468 U.S. 420, 439 , 104 S.Ct. 3138, 3150 , 82 L.Ed.2d 317, 334 (1984), the Supreme Court concluded that a traffic stop was more analogous to a Terry-type stop than a formal arrest.

11
United States v. Hendersongreen
ca1 · 2006 · cited in 1 Iowa opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., United States v. Blair, 524 F.3d 740, 752 (6th Cir.2008) (stating Terry-type stop must be reasonably related in scope to the circumstances which justified the interference in the first place); United States v. Henderson, 463 F.3d 27, 45 (1st Cir.2006) (holding the scope and duration must be reasonably related to the purpose of the vehicle stop).

2011See, e.g., United States v. Blair, 524 F.3d 740, 752 (6th Cir. 2008) (stating Terry-type stop must be reasonably related in scope to the circumstances which justified the interference in the first place); United States v. Henderson, 463 F.3d 27, 45 (lst Cir. 2006) (holding the scope and duration must be reasonably related to the purpose of the vehicle stop).

11
United States v. Blairgreen
ca6 · 2008 · cited in 1 Iowa opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., United States v. Blair, 524 F.3d 740, 752 (6th Cir.2008) (stating Terry-type stop must be reasonably related in scope to the circumstances which justified the interference in the first place); United States v. Henderson, 463 F.3d 27, 45 (1st Cir.2006) (holding the scope and duration must be reasonably related to the purpose of the vehicle stop).

2011See, e.g., United States v. Blair, 524 F.3d 740, 752 (6th Cir. 2008) (stating Terry-type stop must be reasonably related in scope to the circumstances which justified the interference in the first place); United States v. Henderson, 463 F.3d 27, 45 (lst Cir. 2006) (holding the scope and duration must be reasonably related to the purpose of the vehicle stop).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Jones v. State green
del · 1999
2 sentences

2022According to the Jones court, to contend that evidence that was obtained pursuant to an unlawful Terry-type stop is admissible because of events that occurred because of the illegal conduct is “a bootstrap analysis.” Id. at 873 .

2022According to the Jones court, to contend that evidence that was obtained pursuant to an unlawful Terry-type stop is admissible because of events that occurred because of the illegal conduct is “a bootstrap analysis.” Id. at 873 .

22022–2022
State v. Beauchesne green
nh · 2005
2 sentences

2022Similarly, in State v. Beauchesne, the New Hampshire Supreme Court rejected application of the new crime exception where an officer unlawfully grabbed a defendant who then threw something away. 868 A.2d 972, 975 , 983–84 (N.H. 2005).

2022Similarly, in State v. Beauchesne, the New Hampshire Supreme Court rejected application of the new crime exception where an officer unlawfully grabbed a defendant who then threw something away. 868 A.2d 972, 975 , 983–84 (N.H. 2005).

22022–2022

Statutes the citing opinions construe

IA § Iowa Code § 321.37 (4) IA § Iowa Code § 321.174 (3) IA § Iowa Code § 9.3 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MA 32 (1984–2026) GA 18 (1979–2014) IA 10 (2011–2025) IL 9 (1983–2013) MN 8 (1988–2016) ME 7 (1984–2016) TX 6 (1991–2015) NY 5 (1981–1991) VA 4 (1988–2023) OH 4 (1991–2025) MD 4 (1983–2001) MO 3 (1988–2001) PA 2 (2011–2015) IN 2 (1993–2008) NM 2 (1991–2012) AL 2 (1987–1990) FL 2 (1989–1995) HI 2 (1999–2002) OR 2 (1982–1985) MT 2 (2022–2023) LA 2 (1986–1989) CA 2 (1975–1986)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check