State of Iowa v. Charles Aaron Amble and John Joseph Mandracchia

The State was granted discretionary review of the district court’s ruling granting defendants’ motions to suppress evidence obtained following a search warrant that was based on evidence of narcotic activity found in warrantless search of garbage bags outside the defendants’ residence. The district court held Iowa Code section 808.16—which provides that “a person has no reasonable expectation of privacy in garbage placed outside of the person’s residence for waste collection in a publicly accessible area” and that “Garbage placed outside of a person’s residence for waste collection in a publicly accessible area shall be deemed abandoned property”—is void as inconsistent with the language of article I, section 8 of the Iowa Constitution as interpreted by the Iowa Supreme Court in State v. Wright, 961 N.W.2d 396 (Iowa 2021).

Holding: The State appeals the district court’s ruling declaring Iowa Code section 808.16 facially unconstitutional and granting the defendants’ motions to suppress evidence obtained through warrantless searches of garbage. Reversed and Remanded.