State of Iowa v. Jaheim Romaine Cyrus

Summary

The court held that the officer's initial encounter with Cyrus was consensual and did not become a seizure before the officer smelled marijuana. Applying an objective totality-of-the-circumstances test, the court determined that the patrol car's positioning, rear-facing lights, spotlight, and the officer's conduct did not amount to coercion. The court also declined to modify the seizure test to consider Cyrus's age or race, while noting that his alternative strict-scrutiny argument was unpreserved. No separate opinions were filed.