State of Iowa v. Jaheim Romaine Cyrus

Summary

The court held that the officer did not seize Cyrus before smelling burnt marijuana because the officer’s positioning, rear-facing lights, spotlight, and conversational approach did not objectively communicate a command to remain. The court applied the objective totality-of-the-circumstances test and declined to consider Cyrus’s age or race in determining whether a seizure occurred. The court affirmed the suppression ruling and resulting judgment of conviction.