touchstone analysis in Iowa

2019See Pennsylvania v. Mimms, 434 U.S. 106, 108-09 (1977) (“The touchstone of our analysis under the Fourth Amendment is always ‘the reasonableness in all the circumstances of the particular governmental invasion of a citizen’s personal security.’” (citation omitted)).

2019See Pennsylvania v. Mimms, 434 U.S. 106, 108-09 (1977) (“The touchstone of our analysis under the Fourth Amendment is always ‘the reasonableness in all the circumstances of the particular governmental invasion of a citizen’s personal security.’” (citation omitted)); Kreps, 650 N.W.2d at 641 (“The Fourth Amendment imposes a general reasonableness standard upon all searches and seizures.”).

2019See Pennsylvania v. Mimms, 434 U.S. 106, 108-09 (1977) (“The touchstone of our analysis under the Fourth Amendment is always ‘the reasonableness in all the circumstances of the particular governmental invasion of a citizen’s personal security.’” (citation omitted)); Kreps, 650 N.W.2d at 641 (“The Fourth Amendment imposes a general reasonableness standard upon all searches and seizures.”).

2018See Pennsylvania v. Mimms , 434 U.S. 106 , 108-09 (1977) ("The touchstone of our analysis under the Fourth Amendment is always the reasonableness in all circumstances of the particular governmental invasion of a citizen's personal security." (citation omitted) ); State v. Kreps , 650 N.W.2d 636 , 641 (Iowa 2002) ("The Fourth Amendment imposes a general reasonableness standard upon all searches and seizures.").

2017“The touchstone of our analysis under the Fourth Amendment is always ‘the reasonableness in all circumstances of the particular governmental invasion of a citizen’s personal security.’ ” Pennsylvania v. Mimms, 434 U.S. 106, 108-09 , 98 S.Ct. 330, 332 , 54 L.Ed.2d 331, 335 (1977) (quoting Terry v. Ohio, 392 U.S. 1, 19 , 88 S.Ct. 1868, 1878 , 20 L.Ed.2d 889, 904 (1968)).

2017“The touchstone of our analysis under the Fourth Amendment is always ‘the reasonableness in all circumstances of the particular governmental invasion of a citizen’s personal security.’ ” Pennsylvania v. Mimms, 434 U.S. 106, 108-09 , 98 S.Ct. 330, 332 , 54 L.Ed.2d 331, 335 (1977) (quoting Terry v. Ohio, 392 U.S. 1, 19 , 88 S.Ct. 1868, 1878 , 20 L.Ed.2d 889, 904 (1968)).

2019Although the touchstone of any search-and-seizure claim, whether arising under federal or state law, is reasonableness under the circumstances presented, Hampton correctly notes that “[e]ven ‘in . . . cases in which no substantive distinction [appears] between state and federal constitutional provisions, we 3 reserve the right to apply the principles differently under the state constitution compared to its federal counterpart.’” State v. Gaskins, 866 N.W.2d 1, 6 (Iowa 2015) (quoting King v. State, 797 N.W.2d 565, 571 (Iowa 2011)).

2019Although the touchstone of any search-and-seizure claim, whether arising under federal or state law, is reasonableness under the circumstances presented, Hampton correctly notes that “[e]ven ‘in . . . cases in which no substantive distinction [appears] between state and federal constitutional provisions, we 3 reserve the right to apply the principles differently under the state constitution compared to its federal counterpart.’” State v. Gaskins, 866 N.W.2d 1, 6 (Iowa 2015) (quoting King v. State, 797 N.W.2d 565, 571 (Iowa 2011)).

2017We must weigh the “balance between the public interest and the individual’s right to personal security free from arbitrary interference by law officers.” Id. at 109 , 98 S.Ct. at 332 , 54 L.Ed.2d at 336 (quoting United States v. Brignoni-Ponce, 422 U.S. 873, 878 , 95 S.Ct. 2574, 2579 , 45 L.Ed.2d 607, 614-15 (1975)); see also State v. DeWitt, 811 N.W.2d 460, 468 (Iowa 2012) (“[T]he test for reasonableness of police conduct ‘requires a careful balancing of “the nature and quality of the intrusion on the individual’s Fourth Amendment interests” against the countervailing governmental interests a

2017We must weigh the “balance between the public interest and the individual’s right to personal security free from arbitrary interference by law officers.” Id. at 109 , 98 S.Ct. at 332 , 54 L.Ed.2d at 336 (quoting United States v. Brignoni-Ponce, 422 U.S. 873, 878 , 95 S.Ct. 2574, 2579 , 45 L.Ed.2d 607, 614-15 (1975)); see also State v. DeWitt, 811 N.W.2d 460, 468 (Iowa 2012) (“[T]he test for reasonableness of police conduct ‘requires a careful balancing of “the nature and quality of the intrusion on the individual’s Fourth Amendment interests” against the countervailing governmental interests a

2017We must weigh the “balance between the public interest and the individual’s right to personal security free from arbitrary interference by law officers.” Id. at 109 , 98 S.Ct. at 332 , 54 L.Ed.2d at 336 (quoting United States v. Brignoni-Ponce, 422 U.S. 873, 878 , 95 S.Ct. 2574, 2579 , 45 L.Ed.2d 607, 614-15 (1975)); see also State v. DeWitt, 811 N.W.2d 460, 468 (Iowa 2012) (“[T]he test for reasonableness of police conduct ‘requires a careful balancing of “the nature and quality of the intrusion on the individual’s Fourth Amendment interests” against the countervailing governmental interests a

2017We must weigh the “balance between the public interest and the individual’s right to personal security free from arbitrary interference by law officers.” Id. at 109 , 98 S.Ct. at 332 , 54 L.Ed.2d at 336 (quoting United States v. Brignoni-Ponce, 422 U.S. 873, 878 , 95 S.Ct. 2574, 2579 , 45 L.Ed.2d 607, 614-15 (1975)); see also State v. DeWitt, 811 N.W.2d 460, 468 (Iowa 2012) (“[T]he test for reasonableness of police conduct ‘requires a careful balancing of “the nature and quality of the intrusion on the individual’s Fourth Amendment interests” against the countervailing governmental interests a

2017We must weigh the “balance between the public interest and the individual’s right to personal security free from arbitrary interference by law officers.” Id. at 109 , 98 S.Ct. at 332 , 54 L.Ed.2d at 336 (quoting United States v. Brignoni-Ponce, 422 U.S. 873, 878 , 95 S.Ct. 2574, 2579 , 45 L.Ed.2d 607, 614-15 (1975)); see also State v. DeWitt, 811 N.W.2d 460, 468 (Iowa 2012) (“[T]he test for reasonableness of police conduct ‘requires a careful balancing of “the nature and quality of the intrusion on the individual’s Fourth Amendment interests” against the countervailing governmental interests a

2014See, e.g., Wisniewski, 510 F.3d at 301 (“After Sandoval, the relevant inquiry for determining whether a private right of action exists appears to have two steps: (1) Did Congress intend to create a personal right?; and (2) Did Congress intend to create a private remedy?”); Love v. Delta Air Lines, 310 F.3d 1347 , 1351–52 (11th Cir. 2002) (“Since the late 1970s, the Supreme Court has gradually receded from its reliance on three of these four factors, focusing exclusively on legislative intent to create a private right of action as the touchstone of its analysis.

2014See, e.g., Wisniewski, 510 F.3d at 301 (“After Sandoval , the relevant inquiry for determining whether a private right of action exists appears to have two steps: (1) Did Congress intend to create a personal right?; and (2) Did Congress intend to create a private remedy?”); Love v. Delta Air Lines, 310 F.3d 1347, 1351-52 (11th Cir.2002) (“Since the late 1970s, the Supreme Court has gradually receded from its reliance on three of these four factors, focusing exclusively on legislative intent to create a private right of action as the touchstone of its analysis.

2014See, e.g., Wisniewski, 510 F.3d at 301 (“After Sandoval, the relevant inquiry for determining whether a private right of action exists appears to have two steps: (1) Did Congress intend to create a personal right?; and (2) Did Congress intend to create a private remedy?”); Love v. Delta Air Lines, 310 F.3d 1347 , 1351–52 (11th Cir. 2002) (“Since the late 1970s, the Supreme Court has gradually receded from its reliance on three of these four factors, focusing exclusively on legislative intent to create a private right of action as the touchstone of its analysis.

2014See, e.g., Wisniewski, 510 F.3d at 301 (“After Sandoval , the relevant inquiry for determining whether a private right of action exists appears to have two steps: (1) Did Congress intend to create a personal right?; and (2) Did Congress intend to create a private remedy?”); Love v. Delta Air Lines, 310 F.3d 1347, 1351-52 (11th Cir.2002) (“Since the late 1970s, the Supreme Court has gradually receded from its reliance on three of these four factors, focusing exclusively on legislative intent to create a private right of action as the touchstone of its analysis.

2014Sandoval is the culmination of this trend . . . .” (Footnote omitted.)); Leach v. Mediacom, 240 F. Supp. 2d 994, 997 (S.D.

2014Sandoval is the culmination of this trend.... ” (Footnote omitted.)); Leach v. Mediacom, 240 F.Supp.2d 994, 997 (S.DJowa 2003) (“Sandoval clarifies the proper approach for courts to take when analyzing implied rights of action.

2009Rather, the touchstone of the analysis should be “whether the group lacks sufficient political strength to bring a prompt end to the prejudice and discrimination through traditional political means.” Id. at 444.

2000United States v. Bajakajian, 524 U.S. 321, 327 , 118 S.Ct. 2028, 2033 , 141 L.Ed.2d 314, 325 (1998).

2000United States v. Bajakajian, 524 U.S. 321, 327 , 118 S.Ct. 2028, 2033 , 141 L.Ed.2d 314, 325 (1998).