Clarke County Sheriff’s Deputies responded to a single car in the ditch accident. Law enforcement was advised someone had been seen walking from the accident. As the deputy was at the scene of the accident, he observed a van drive past him and away from the scene. Another deputy advised him the van had pulled into the driveway of a residence and drive back out. Deputies followed the van, ran the license plate, and determined the van and the car in the ditch were registered to the same address. The deputy stopped the van stating that he was either making sure the driver of the van needed assistance finding the driver of the car or if the driver of the car was in the van he may need medical assistance. The Iowa Supreme Court overturned the district court and Iowa Court of Appeals’ decision, holding that the deputy was not performing a valid community caretaking duty, but was actually performing an investigation and that the stop of the van was unconstitutional.
