automobile exception in Iowa

2025One of those well-delineated exceptions is the automobile exception. “[T]his exception is applicable when probable cause and exigent circumstances exist at the time the car is stopped by police.” Storm, 898 N.W.2d at 145 (alteration in original) (quoting State v. Holderness, 301 N.W.2d 733, 736 (Iowa 1981)).

2025See Storm, 898 N.W.2d at 156 (retaining the automobile exception under the Iowa Constitution); State v. Delgado-Jimenez, No. 19-0746, 2020 WL 115768 , at *2 (Iowa Ct. App. Jan. 9, 2020) (applying the automobile exception to an unoccupied parked car).

2025See, e.g., State v. Allensworth, 748 N.W.2d 789, 797 (Iowa 2008) (applying the automobile exception to permit a warrantless search of a vehicle); State v. Eubanks, 355 N.W.2d 57, 59 (Iowa 1984) (“It is well established that a police officer may search an automobile without a warrant when probable cause and exigent circumstances exist.”); Holderness, 301 N.W.2d at 736 (recognizing the automobile exception to the general warrant requirement).

2025See, e.g., State v. Allensworth, 748 N.W.2d 789, 797 (Iowa 2008) (applying the automobile exception to permit a warrantless search of a vehicle); State v. Eubanks, 355 N.W.2d 57, 59 (Iowa 1984) (“It is well established that a police officer may search an automobile without a warrant when probable cause and exigent circumstances exist.”); Holderness, 301 N.W.2d at 736 (recognizing the automobile exception to the general warrant requirement).

2025We noted that we first adopted the automobile exception in 1980 in State v. Olsen, 293 N.W.2d 216, 220 (Iowa 1980).

2025We first recognized the automobile exception under the Iowa Constitution forty-five years ago in Olsen, 293 N.W.2d at 220 .

2025One of those well-delineated exceptions is the automobile exception. “[T]his exception is applicable when probable cause and exigent circumstances exist at the time the car is stopped by police.” Storm, 898 N.W.2d at 145 (alteration in original) (quoting State v. Holderness, 301 N.W.2d 733, 736 (Iowa 1981)).

2025See, e.g., State v. Allensworth, 748 N.W.2d 789, 797 (Iowa 2008) (applying the automobile exception to permit a warrantless search of a vehicle); State v. Eubanks, 355 N.W.2d 57, 59 (Iowa 1984) (“It is well established that a police officer may search an automobile without a warrant when probable cause and exigent circumstances exist.”); Holderness, 301 N.W.2d at 736 (recognizing the automobile exception to the general warrant requirement).

2017The United States Supreme Court first recognized the automobile exception to the search- warrant requirement in Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 (1925).

2017The United States Supreme Court first recognized the automobile exception to the search- warrant requirement in Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 (1925).

2021Gaskins does not preclude a warrantless breath test incident to an arrest; to the contrary, Gaskins expressly allows a warrantless SITA to “preserv[e] evidence from destruction.” See 866 N.W.2d at 14 ; see also Birchfield, 579 U.S. at ___ , 136 S. Ct. at 2182 (equating “preventing the loss of blood alcohol evidence as the result of the body’s metabolism of alcohol” with 6We subsequently held such searches are still allowed under the automobile exception to the warrant requirement.

2021Gaskins does not preclude a warrantless breath test incident to an arrest; to the contrary, Gaskins expressly allows a warrantless SITA to “preserv[e] evidence from destruction.” See 866 N.W.2d at 14 ; see also Birchfield, 579 U.S. at ___ , 136 S. Ct. at 2182 (equating “preventing the loss of blood alcohol evidence as the result of the body’s metabolism of alcohol” with 6We subsequently held such searches are still allowed under the automobile exception to the warrant requirement.

2017In determining whether the probable-cause-and-exigent-circumstances exception applies, “[w]e have previously applied the ‘inherent exigency’ rationale for warrantless probable-cause searches and seizures of readily mobile vehicles.” Id. at 795 (citing State v. Cain, 400 N.W.2d 582, 585 (Iowa 1987) (“[T]he exigency requirement is always satisfied by a vehicle’s inherent mobility.”)). “[U]nder the automobile exception which was created in recognition of the decreased expectation of privacy accorded to a vehicle and the exigencies 10 associated with it, a warrantless search of a vehicle may be ma

2017See, e.g., State v. Holderness, 301 N.W.2d 733, 737 (Iowa 1981) (“These facts, coupled with the inherent mobility of the vehicle, created a clear likelihood that the car and its contents might never have been located again had the police departed to obtain a warrant.” (Emphasis added.)); State v. Lam, 391 N.W.2d 245, 249 (Iowa 1986) (“If the automobile had not been seized immediately, there was a clear likelihood that the car and its contents may never have been located again had the police departed to obtain a search warrant.” (Emphasis added.)). 41 Importantly, from our earliest cases applyi

2017See, e.g., Allensworth, 748 N.W.2d at 791 n.2 (rejecting an Iowa constitutional challenge to a warrantless vehicle search); State v. Maddox, 670 N.W.2d 168, 171 (Iowa 2003) (applying the automobile exception to uphold a warrantless search under the Federal and Iowa Constitutions because of a vehicle’s “inherent mobility”); Holderness, 301 N.W.2d at 737 (rejecting federal and state constitutional challenges to a warrantless vehicle search conducted at the police station); see also State v. Vance, 790 N.W.2d 775, 791 (Iowa 2010) (Cady, J., dissenting) (“This [automobile] exception has been firml

2017See, e.g., Allensworth, 748 N.W.2d at 791 n.2 (rejecting an Iowa constitutional challenge to a warrantless vehicle search); State v. Maddox, 670 N.W.2d 168, 171 (Iowa 2003) (applying the automobile exception to uphold a warrantless search under the Federal and Iowa Constitutions because of a vehicle’s “inherent mobility”); Holderness, 301 N.W.2d at 737 (rejecting federal and state constitutional challenges to a warrantless vehicle search conducted at the police station); see also State v. Vance, 790 N.W.2d 775, 791 (Iowa 2010) (Cady, J., dissenting) (“This [automobile] exception has been firml

2025See, e.g., California v. Carney, 471 U.S. 386 , 393–94 (1985) (applying the automobile exception based upon “a reduced expectation of privacy stemming from its use as a licensed motor vehicle subject to a range of police regulation inapplicable to a fixed dwelling”); Chambers v. Maroney, 399 U.S. 42, 52 (1970) (identifying the exigency presented by the mobility of automobiles saying that 14 “there is little to choose in terms of practical consequences between an immediate search without a warrant and the car’s immobilization until a warrant is obtained”).

2025See, e.g., California v. Carney, 471 U.S. 386 , 393–94 (1985) (applying the automobile exception based upon “a reduced expectation of privacy stemming from its use as a licensed motor vehicle subject to a range of police regulation inapplicable to a fixed dwelling”); Chambers v. Maroney, 399 U.S. 42, 52 (1970) (identifying the exigency presented by the mobility of automobiles saying that 14 “there is little to choose in terms of practical consequences between an immediate search without a warrant and the car’s immobilization until a warrant is obtained”).

2025See, e.g., California v. Carney, 471 U.S. 386 , 393–94 (1985) (applying the automobile exception based upon “a reduced expectation of privacy stemming from its use as a licensed motor vehicle subject to a range of police regulation inapplicable to a fixed dwelling”); Chambers v. Maroney, 399 U.S. 42, 52 (1970) (identifying the exigency presented by the mobility of automobiles saying that 14 “there is little to choose in terms of practical consequences between an immediate search without a warrant and the car’s immobilization until a warrant is obtained”).

2025See, e.g., California v. Carney, 471 U.S. 386 , 393–94 (1985) (applying the automobile exception based upon “a reduced expectation of privacy stemming from its use as a licensed motor vehicle subject to a range of police regulation inapplicable to a fixed dwelling”); Chambers v. Maroney, 399 U.S. 42, 52 (1970) (identifying the exigency presented by the mobility of automobiles saying that 14 “there is little to choose in terms of practical consequences between an immediate search without a warrant and the car’s immobilization until a warrant is obtained”).

2020The trial court denied Domenig’s motion to suppress, concluding the search fell under the automobile exception to the warrant requirement. “[T]he automobile exception to the fourth amendment requirement of a search warrant is applicable if probable cause and exigent circumstances exist at the time the automobile is 3 stopped by police.” State v. Edgington, 487 N.W.2d 675, 678 (Iowa 1992).

2008See Edgington, 487 N.W.2d at 677–78 (“Previously, we have stated that the automobile exception to the fourth amendment requirement of a search warrant is applicable if probable cause and exigent circumstances exist at the time the automobile is stopped by police.”); Holderness, 301 N.W.2d at 736–37 (“[E]xigent circumstances are necessary only initially; the absence of exigent circumstances at the time of the actual search is irrelevant.”); see also State v. Olsen, 293 N.W.2d 216, 220 (Iowa 1980) (“It is now clear that the absence of exigent circumstances for the later search is wholly irreleva

2025“Prolonged encounters along the shoulder of the highway pose[] [an] ‘unacceptable risk of serious bodily injury and death.’ ” Storm, 898 N.W.2d at 151 (quoting State v. Witt, 126 A.3d 850, 853 (N.J. 2015)).

2025“Prolonged encounters along the shoulder of the highway pose[] [an] ‘unacceptable risk of serious bodily injury and death.’ ” Storm, 898 N.W.2d at 151 (quoting State v. Witt, 126 A.3d 850, 853 (N.J. 2015)).

2017See Commonwealth v. Gary, 91 A.3d 102, 126 (Pa. 2014) (“[A] generally enhanced concern for individual privacy” does not “translate[] into a conferral of increased privacy protection in every context in which it is asserted under [the state constitution.]”); see also Stout v. State, 898 S.W.2d 457, 460 (Ark. 1995) (“Of course, we could hold that the Arkansas Constitution provides greater protection against unreasonable searches than does the Constitution of the United States, but we see no reason to do so.”); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (noting “the Supreme Court’s interpre

2017See Commonwealth v. Gary, 91 A.3d 102, 126 (Pa. 2014) (“[A] generally enhanced concern for individual privacy” does not “translate[] into a conferral of increased privacy protection in every context in which it is asserted under [the state constitution.]”); see also Stout v. State, 898 S.W.2d 457, 460 (Ark. 1995) (“Of course, we could hold that the Arkansas Constitution provides greater protection against unreasonable searches than does the Constitution of the United States, but we see no reason to do so.”); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (noting “the Supreme Court’s interpre

2017See, e.g., Allensworth, 748 N.W.2d at 791 n.2 (rejecting an Iowa constitutional challenge to a warrantless vehicle search); State v. Maddox, 670 N.W.2d 168, 171 (Iowa 2003) (applying the automobile exception to uphold a warrantless search under the Federal and Iowa Constitutions because of a vehicle’s “inherent mobility”); Holderness, 301 N.W.2d at 737 (rejecting federal and state constitutional challenges to a warrantless vehicle search conducted at the police station); see also State v. Vance, 790 N.W.2d 775, 791 (Iowa 2010) (Cady, J., dissenting) (“This [automobile] exception has been firml

2017See, e.g., Allensworth, 748 N.W.2d at 791 n.2 (rejecting an Iowa constitutional challenge to a warrantless vehicle search); State v. Maddox, 670 N.W.2d 168, 171 (Iowa 2003) (applying the automobile exception to uphold a warrantless search under the Federal and Iowa Constitutions because of a vehicle’s “inherent mobility”); Holderness, 301 N.W.2d at 737 (rejecting federal and state constitutional challenges to a warrantless vehicle search conducted at the police station); see also State v. Vance, 790 N.W.2d 775, 791 (Iowa 2010) (Cady, J., dissenting) (“This [automobile] exception has been firml

2015E.g., State v. Winfrey, 24 A.3d 1218, 1224 (Conn. 2011) (allowing warrantless search of vehicle on probable cause); State v. Charpentier, 962 P.2d 1033, 1036 (Idaho 1998) (concluding the Idaho Constitution provided no greater protection than the Fourth Amendment); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (“We believe that the Supreme Court’s 87 interpretation of the automobile exception, announced in Ross, achieves a fair balance between these competing objectives, and we see no reason at this time to adopt a different standard in applying Illinois constitutional provisions.”); Chavies

2015E.g., State v. Winfrey, 302 Conn. 195 , 24 A.3d 1218, 1224 (2011) (allowing warrantless search of vehicle on probable cause); State v. Charpentier, 131 Idaho 649 , 962 P.2d 1033, 1036 (1998) (concluding the Idaho Constitution provided no greater protection than the Fourth Amendment); People v. Smith, 95 Ill.2d 412 , 69 Ill.Dec. 374 , 447 N.E.2d 809, 813 (1983) (“We believe that the Supreme Court’s interpretation of the automobile exception, announced in Ross, achieves a fair balance between these competing objectives, and we see no reason at this time to adopt a different standard in applying

2017Storm relies on the decisions of five state courts that do not recognize the automobile exception. 6 See State v. Elison, 14 P.3d 456, 471 (Mont. 2000); State v. Sterndale, 656 A.2d 409, 411 (N.H. 1995); State v. Gomez, 932 P.2d 1, 12 (N.M. 1997); State v. Bauder, 924 A.2d 38, 50 (Vt. 2007); State v. Tibbles, 236 P.3d 885, 888 (Wash. 2010).

2017Storm relies on the decisions of five state courts that do not recognize the automobile exception. 6 See State v. Elison, 14 P.3d 456, 471 (Mont. 2000); State v. Sterndale, 656 A.2d 409, 411 (N.H. 1995); State v. Gomez, 932 P.2d 1, 12 (N.M. 1997); State v. Bauder, 924 A.2d 38, 50 (Vt. 2007); State v. Tibbles, 236 P.3d 885, 888 (Wash. 2010).

2015E.g., State v. Winfrey, 24 A.3d 1218, 1224 (Conn. 2011) (allowing warrantless search of vehicle on probable cause); State v. Charpentier, 962 P.2d 1033, 1036 (Idaho 1998) (concluding the Idaho Constitution provided no greater protection than the Fourth Amendment); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (“We believe that the Supreme Court’s 87 interpretation of the automobile exception, announced in Ross, achieves a fair balance between these competing objectives, and we see no reason at this time to adopt a different standard in applying Illinois constitutional provisions.”); Chavies

2015E.g., State v. Winfrey, 302 Conn. 195 , 24 A.3d 1218, 1224 (2011) (allowing warrantless search of vehicle on probable cause); State v. Charpentier, 131 Idaho 649 , 962 P.2d 1033, 1036 (1998) (concluding the Idaho Constitution provided no greater protection than the Fourth Amendment); People v. Smith, 95 Ill.2d 412 , 69 Ill.Dec. 374 , 447 N.E.2d 809, 813 (1983) (“We believe that the Supreme Court’s interpretation of the automobile exception, announced in Ross, achieves a fair balance between these competing objectives, and we see no reason at this time to adopt a different standard in applying

2017See Commonwealth v. Gary, 91 A.3d 102, 126 (Pa. 2014) (“[A] generally enhanced concern for individual privacy” does not “translate[] into a conferral of increased privacy protection in every context in which it is asserted under [the state constitution.]”); see also Stout v. State, 898 S.W.2d 457, 460 (Ark. 1995) (“Of course, we could hold that the Arkansas Constitution provides greater protection against unreasonable searches than does the Constitution of the United States, but we see no reason to do so.”); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (noting “the Supreme Court’s interpre

2017See Commonwealth v. Gary, 91 A.3d 102, 126 (Pa. 2014) (“[A] generally enhanced concern for individual privacy” does not “translate[] into a conferral of increased privacy protection in every context in which it is asserted under [the state constitution.]”); see also Stout v. State, 898 S.W.2d 457, 460 (Ark. 1995) (“Of course, we could hold that the Arkansas Constitution provides greater protection against unreasonable searches than does the Constitution of the United States, but we see no reason to do so.”); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (noting “the Supreme Court’s interpre

2017The United States Supreme Court has also justified the automobile exception based on the reduced expectation of privacy resulting from the “configuration, use and regulation of automobiles.” Arkansas v. Sanders, 442 U.S. 753, 761 , 99 S. Ct. 2586, 2591 (1979), abrogated on other grounds by Acevedo, 500 U.S. at 575 , 111 S. Ct. at 1989 .

2017The United States Supreme Court has also justified the automobile exception based on the reduced expectation of privacy resulting from the “configuration, use and regulation of automobiles.” Arkansas v. Sanders, 442 U.S. 753, 761 , 99 S. Ct. 2586, 2591 (1979), abrogated on other grounds by Acevedo, 500 U.S. at 575 , 111 S. Ct. at 1989 .

2017See Commonwealth v. Gary, 91 A.3d 102, 126 (Pa. 2014) (“[A] generally enhanced concern for individual privacy” does not “translate[] into a conferral of increased privacy protection in every context in which it is asserted under [the state constitution.]”); see also Stout v. State, 898 S.W.2d 457, 460 (Ark. 1995) (“Of course, we could hold that the Arkansas Constitution provides greater protection against unreasonable searches than does the Constitution of the United States, but we see no reason to do so.”); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (noting “the Supreme Court’s interpre

2017See Commonwealth v. Gary, 91 A.3d 102, 126 (Pa. 2014) (“[A] generally enhanced concern for individual privacy” does not “translate[] into a conferral of increased privacy protection in every context in which it is asserted under [the state constitution.]”); see also Stout v. State, 898 S.W.2d 457, 460 (Ark. 1995) (“Of course, we could hold that the Arkansas Constitution provides greater protection against unreasonable searches than does the Constitution of the United States, but we see no reason to do so.”); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (noting “the Supreme Court’s interpre

2022In Wyoming v. Houghton, in holding that probable cause to search a vehicle for contraband extended to searching a passenger’s bag that might contain the contraband, Justice Scalia distinguished between the diminished privacy associated with a passenger’s belongings found in a vehicle and “the unique, significantly heightened protection afforded against searches of one’s person.” 526 U.S. 295, 303 (1999) (distinguishing Di Re, 332 U.S. 581 , and Ybarra v. Illinois, 444 U.S. 85 (1979)); see also id. at 307–08 (Breyer, J., concurring) (writing separately to highlight that the bright-line rule for

2022Ky. 2009) (“[W]hile [the automobile exception] may justify a search of the car’s interior and the personal possessions of its occupants found therein, it will not alone justify the warrantless search of the vehicle’s occupants themselves.” (citing Houghton, 526 U.S. at 303 & n.1)); Cady v. State, 817 So. 2d 948, 949 (Fla. Dist.

2017In determining whether the probable-cause-and-exigent-circumstances exception applies, “[w]e have previously applied the ‘inherent exigency’ rationale for warrantless probable-cause searches and seizures of readily mobile vehicles.” Id. at 795 (citing State v. Cain, 400 N.W.2d 582, 585 (Iowa 1987) (“[T]he exigency requirement is always satisfied by a vehicle’s inherent mobility.”)). “[U]nder the automobile exception which was created in recognition of the decreased expectation of privacy accorded to a vehicle and the exigencies 10 associated with it, a warrantless search of a vehicle may be ma

2008State v. Cain, 400 N.W.2d 582, 585 (Iowa 1987) (noting “recent decisions of the United States Supreme Court and this court ... have made it clear that the exigency requirement is always satisfied by a vehicle’s inherent mobility”); Lam, 391 N.W.2d at 248 (“The Court’s decision [in Carney ] makes it clear that under the automobile exception which was created in recognition of the decreased expectation of privacy accorded to a vehicle and the exigencies associated •with it, a warrantless search of a vehicle may be made if the authorities have probable cause.”).

2025See, e.g., State v. Allensworth, 748 N.W.2d 789, 797 (Iowa 2008) (applying the automobile exception to permit a warrantless search of a vehicle); State v. Eubanks, 355 N.W.2d 57, 59 (Iowa 1984) (“It is well established that a police officer may search an automobile without a warrant when probable cause and exigent circumstances exist.”); Holderness, 301 N.W.2d at 736 (recognizing the automobile exception to the general warrant requirement).

2025See, e.g., State v. Allensworth, 748 N.W.2d 789, 797 (Iowa 2008) (applying the automobile exception to permit a warrantless search of a vehicle); State v. Eubanks, 355 N.W.2d 57, 59 (Iowa 1984) (“It is well established that a police officer may search an automobile without a warrant when probable cause and exigent circumstances exist.”); Holderness, 301 N.W.2d at 736 (recognizing the automobile exception to the general warrant requirement).

2019For example, the New Hampshire Supreme Court rejected the automobile exception in State v. Sterndale , 139 N.H. 445 , 656 A.2d 409 , 411-12 (N.H. 1995), abrogated in part on other grounds by State v. Goss , 150 N.H. 46 , 834 A.2d 316 , 318-19 (N.H. 2003), as *892 recognized in State v. Cora , 170 N.H. 186 , 167 A.3d 633 , 641-42 (N.H. 2017), the Minnesota Supreme Court rejected Atwater in State v. Askerooth , 681 N.W.2d 353 , 361-63 (Minn. 2004) (en banc), the New Jersey Supreme Court rejected application of Schneckloth to an automobile stop in State v. Carty , 170 N.J. 632 , 790 A.2d 903 , 90

2019For example, the New Hampshire Supreme Court rejected the automobile exception in State v. Sterndale , 139 N.H. 445 , 656 A.2d 409 , 411-12 (N.H. 1995), abrogated in part on other grounds by State v. Goss , 150 N.H. 46 , 834 A.2d 316 , 318-19 (N.H. 2003), as *892 recognized in State v. Cora , 170 N.H. 186 , 167 A.3d 633 , 641-42 (N.H. 2017), the Minnesota Supreme Court rejected Atwater in State v. Askerooth , 681 N.W.2d 353 , 361-63 (Minn. 2004) (en banc), the New Jersey Supreme Court rejected application of Schneckloth to an automobile stop in State v. Carty , 170 N.J. 632 , 790 A.2d 903 , 90

2008An automobile exception search may be “as thorough as a magistrate could authorize in a warrant particularly describing the place to be searched.” Ross, 456 U.S. at 800 , 102 S. Ct. at 2159 , 72 L.

2008An automobile exception search may be “as thorough as a magistrate could authorize in a warrant particularly describing the place to be searched.” Ross, 456 U.S. at 800 , 102 S. Ct. at 2159 , 72 L.

2017See Commonwealth v. Gary, 91 A.3d 102, 126 (Pa. 2014) (“[A] generally enhanced concern for individual privacy” does not “translate[] into a conferral of increased privacy protection in every context in which it is asserted under [the state constitution.]”); see also Stout v. State, 898 S.W.2d 457, 460 (Ark. 1995) (“Of course, we could hold that the Arkansas Constitution provides greater protection against unreasonable searches than does the Constitution of the United States, but we see no reason to do so.”); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (noting “the Supreme Court’s interpre

2017See Commonwealth v. Gary, 91 A.3d 102, 126 (Pa. 2014) (“[A] generally enhanced concern for individual privacy” does not “translate[] into a conferral of increased privacy protection in every context in which it is asserted under [the state constitution.]”); see also Stout v. State, 898 S.W.2d 457, 460 (Ark. 1995) (“Of course, we could hold that the Arkansas Constitution provides greater protection against unreasonable searches than does the Constitution of the United States, but we see no reason to do so.”); People v. Smith, 447 N.E.2d 809, 813 (Ill. 1983) (noting “the Supreme Court’s interpre

2017The Supreme Court reversed, noting that “under our established precedent, the ‘automobile exception’ has no separate exigency requirement.” Id. at 466 , 119 S. Ct. at 2014 ; see also Pennsylvania v. Labron, 518 U.S. 938, 940 , 116 S. Ct. 2485, 2487 (1996) (per curiam) (using the automobile exception to justify a search based only on probable cause with no additional exigency). 2.

2017The Supreme Court reversed, noting that “under our established precedent, the ‘automobile exception’ has no separate exigency requirement.” Id. at 466 , 119 S. Ct. at 2014 ; see also Pennsylvania v. Labron, 518 U.S. 938, 940 , 116 S. Ct. 2485, 2487 (1996) (per curiam) (using the automobile exception to justify a search based only on probable cause with no additional exigency). 2.