Between emerging legislation and courtroom decisions, state and federal laws are everchanging. Meanwhile, police officers are expected to not only keep up with those changes, but to effectively enforce these laws in their communities. Falling behind can result in procedural mistakes, costly lawsuits, lengthy trials, inadmissible evidence, and poor reputations.
The following cases from the United States Court of Appeals for the Eighth Circuit and from the Iowa Court of Appeals demonstrate missteps by law enforcement and emphasize the importance of staying updated on current laws.
Wheeler v. City of Searcy, Arkansas: Insufficient Probable Cause For Arrest Warrant
Decided
September 29, 2021
Involved
Plaintiff: Brandon Lee Wheeler
Defendants: Searcy Police Department officers
Issue in question
Whether police officers who signed a misleading warrant affidavit that led to an unconstitutional arrest would be entitled to qualified immunity where the prosecutor had reviewed and approved the affidavit and a judge had signed the warrant.
Details
During a missing person investigation, Searcy police submitted a misleading and incomplete affidavit for Brandon Wheeler's arrest for capital murder and abuse of a corpse. The affidavit included a key-witness statement that had been recanted. It also incorrectly implied that the victim’s body had been recovered.
After his arrest (and eventual release), Wheeler filed a civil lawsuit, claiming officers violated his Fourth Amendment rights by knowingly or recklessly omitting material facts from the warrant affidavit.
In 2020, the United States District Court for the Eastern District of Arkansas found that after removing the misleading statements from the affidavit, the affidavit was insufficient to establish probable cause to arrest Wheeler. The Eighth Circuit Court of Appeals affirmed that decision in 2021.
Outcome
Without the misleading information in the affidavit, there was no probable cause to arrest Wheeler for capital murder or abuse of a corpse.
Under normal circumstances, a prosecutor’s and judge’s review and approval of the affidavit and warrant would be enough to show that the officers acted in good faith in executing the warrant. However, where the officers misled the prosecutor and judge by omitting important facts and overstating the evidence, the officers had to know the warrant was improper.
Because the officers' reliance on the warrant was not in good faith, they were not entitled to qualified immunity for their actions in executing the warrant. The plaintiff’s lawsuit against them was allowed to proceed.
Source Wheeler v. City of Searcy, 14 F.4th 843 (8th Cir. 2021).
Haynes v. Minnehan (Des Moines): Handcuffing Without a Valid Threat
Decided
September 21, 2021
Involved
Plaintiff: Dejuan Haynes
Defendant: Officer Brian Minnehan
Issue in question
Whether or not the initially lawful Terry stop ultimately violated the plaintiff’s Fourth Amendment rights, as the officers had fair notice that they could not handcuff the plaintiff without an objective safety concern.
Details
Des Moines police officers were investigating a reported drug deal when they stopped Dejuan Haynes, who was lawfully questioned as a suspect.
During the exchange, Haynes was cooperative and posed no apparent safety risk. Despite this, he was handcuffed by one of the officers. According to bodycam and dashcam footage, he stayed handcuffed during and after the clean pocket search and continued to cooperate. After a thorough pat down, officers uncuffed and released Haynes.
Haynes later filed a civil lawsuit against the officers for violating his Fourth Amendment rights by keeping him in handcuffs without an objective safety concern.
While the district court determined that the officers were entitled to have the case dismissed based on qualified immunity, the Eight Circuit Court of Appeals reversed the decision in 2021. The court concluded that the officers failed to provide evidence that Haynes presented a safety concern.
Outcome
The law was clearly established that if suspects are cooperative and officers have no objective concerns for safety, the officers may not use intrusive tactics such as handcuffing absent any extraordinary circumstances. Accordingly, the officers were not entitled to qualified immunity and the plaintiff’s case against them could proceed.
Source Haynes v. Minnehan, 14 F.4th 830 (8th Cir. 2021).
State v. Stark: Interrogation Without Miranda Rights
Decided
October 6, 2021
Involved
Plaintiff: State of Iowa
Defendant: Jaymes Anthony Stark
Issue in question
Whether or not the defendant was considered "in custody" when questioned by police officers.
Details
In the spring of 2020, police were called to the scene after a Keokuk woman reported her checkbooks had been stolen from her car. When police arrived, they found suspect Jaymes Stark in the parking lot.
While a patrol car’s emergency lights flashed, one of three responding officers questioned Stark for about 20 minutes, saying, “I’m trying to help you avoid going to jail here,” and presenting him with evidence of his guilt. Law enforcement did not read Starck a Miranda warning during the questioning and later transported him to the police station. Stark was eventually issued a citation and later charged with burglary.
Stark later appealed his conviction, claiming his statements to police should have been suppressed because he was in custody when questioned by officers but not read a Miranda warning. In 2021, the Iowa Court of Appeals held that a reasonable person in Stark’s position would have felt his freedom was curtailed during the interrogation, so officers should have first provided a Miranda warning.
Outcome
Stark’s conviction was reversed and he is entitled to a new trial, during which his incriminating statements will not be admissible against him.
Source https://www.iowacourts.gov/courtcases/13637/embed/CourtAppealsOpinion
Iowa State v. Flanagan: Exceeding Scope in a Traffic Stop
Decided
October 6, 2021
Involved
Plaintiff: State of Iowa
Defendant: James Flanagan
Issue in question
Whether a state trooper unlawfully extended the traffic stop by placing the driver in his patrol car and investigating him for an OWI.
Details
While driving near the Yellow Banks Park campgrounds, James Flanagan was pulled over when an Iowa state trooper noticed Flanagan's passenger was not wearing a seatbelt.
In conducting the routine traffic stop, the trooper noticed the driver's "nervousness and reddened eyes," and asked Flanagan to come back to his patrol car. He then was asked to complete field sobriety tests, which indicated intoxication. The State charged Flanagan with OWI.
Flanagan claimed the trooper had no reasonable suspicion for conducting the field sobriety tests during the seatbelt-related stop, and moved to suppress evidence.
The district court denied the motion and a jury convicted Flangan. Flanagan appealed. The Iowa Court of Appeals then reversed the trial court’s suppression ruling, concluding the passenger’s infraction did not provide the trooper sufficient cause to ask the driver to move to his patrol car for questioning. Accordingly, the trooper exceeded his authority and improperly prolonged the stop.
Outcome
All evidence obtained after the trooper placed the driver in the patrol car must be suppressed. Flanagan’s OWI conviction was reversed.
Source https://www.iowacourts.gov/courtcases/13883/embed/CourtAppealsOpinion
PLS offers training to prevent these types of situations from occurring by ensuring law enforcement agencies are up-to-date on Missouri and Iowa state laws. Our training is online, easy to use, and written by attorneys. Lessons address issues such as search and seizure law, interrogations, sobriety investigations, use of force, bias prevention, racial profiling, de-escalation, mental illness, officer mental health, crisis management, suicide intervention, sexual harassment, ethics, and other current issues in law enforcement. Explore Legal Update for more information.