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

Summary

The court held that Iowa Code section 808.16(3), which deems garbage placed in a publicly accessible area for collection to be abandoned property, is constitutional facially and as applied to the defendants. Because the garbage was abandoned by operation of that provision, police did not violate article I, section 8 by conducting warrantless trash pulls, and the resulting evidence supported the warrant to search the home. The court therefore reversed the suppression ruling and remanded for further proceedings.