State of Iowa v. Landin Joseph Howell

── State of Iowa v. Landin Joseph Howell ── Court: Court of Appeals of Iowa Date: April 29, 2026 Category: General IN THE COURT OF APPEALS OF IOWA _______________ No. 24-1976 Filed April 29, 2026 _______________ State of Iowa, Plaintiff–Appellee, v. Landin Joseph Howell, Defendant–Appellant. _______________ Appeal from the Iowa District Court for Story County, The Honorable Stephen A. Owen, Judge. _______________ AFFIRMED _______________ Leah Patton of Patton Legal Services, LLC, Ames, attorney for appellant. Brenna Bird, Attorney General, and Timothy M. Hau, Assistant Attorney General, attorneys for appellee. _______________ Considered without oral argument by Ahlers, P.J., and Buller and Sandy, JJ. Opinion by Sandy, J. 1 SANDY, Judge. A late-night encounter at a gas station resulted in the warrantless search of a parked vehicle following a lawful arrest. Yet whatever constitutional question those facts might invite, we do not reach it here, as the argument now advanced was not preserved in the district court. And because that argument was not preserved, we affirm without reaching the constitutional question. BACKGROUND FACTS AND PROCEEDINGS In April 2024, law enforcement encountered Landin Howell at a gas station in Ames, Iowa, where his vehicle was parked at a gas pump with the engine off. Prior to initiating contact, an officer ran the vehicle’s registration and learned that Howell, the registered owner, had an outstanding arrest warrant. The officer approached Howell as he walked between the pumps and the convenience store and confirmed his identity. Howell was detained while the officer verified the warrant, during which time Howell considered options for securing his vehicle. Ultimately, Howell elected to have the vehicle towed rather than moved or left at the scene. After confirmation of the warrant, Howell was arrested. A search incident to arrest revealed an item the officer identified, based on training and experience, as drug paraphernalia. Specifically, an empty pen tube with burn marks and bite marks wrapped in tape, which the officer identified as an item used to consume narcotics. Howell was then escorted to the convenience store restroom by a second officer while the arresting officer searched Howell’s vehicle. The search occurred before the arrival of a tow truck and without a warrant. During the search, officers discovered items including a pill bottle and materials consistent with drug use. Subsequent testing confirmed the presence of a controlled substance—fentanyl. 2  The State charged Howell with possession of a controlled substance and possession of a prescription drug or device without a valid prescription. Howell filed a motion to suppress, challenging both statements obtained by police during the encounter and that the warrantless search of his vehicle lacked sufficient probable cause. The State conceded that most of Howell’s statements were obtained in violation of Miranda and should be suppressed but resisted suppression of the physical evidence obtained from the vehicle search. Following an evidentiary hearing, the district court granted the motion in part and denied it in part. The court suppressed the statements obtained through custodial interrogation but upheld the search of the vehicle under the automobile exception to the warrant requirement. In doing so, the court concluded that sufficient probable cause existed. Howell subsequently waived his right to a jury trial and proceeded to a bench trial on the