Supreme Court of Iowa

State of Iowa v. Hope Jennifer Clark

May 23, 2025

Summary

The court affirmed Clark’s operating-while-intoxicated conviction, holding that the deputies did not violate Iowa Code section 804.20. The approximately eleven-minute administrative process before the deputies offered her an opportunity to call an attorney did not constitute unnecessary delay, and the deputies provided a reasonable opportunity by repeatedly telling her she could call while placing her phone within reach. The court otherwise left the court of appeals’ resolution of the sufficiency and hearsay issues undisturbed.