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

Summary

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