Officer Shutts approached the car to speak with the occupants. Elder, the defendant in this case, was in the vehicle with a female passenger. He told Officer Shutts that they were "just talking." Officer Shutts noticed the smell of alcoholic beverages coming from the vehicle. Eventually, Elder was arrested and charged with Operating While Intoxicated.
One of the issues the Iowa Court of Appeals answered was whether the police officer could detain the occupants of the car based upon his observation of moisture on the windows and movement inside of the vehicle. The Court of Appeals said no. The Court held that the police officer's vehicle stop was not justified by reasonable suspicion that criminal activity was afoot, and therefore, reversed and found in favor of the defendant.
The State also tried to argue that the police officer was justified in his investigation according to the community caretaking function, and it was only after smelling alcoholic beverages that provided him with the requisite probable cause. The Appeals' Court disagreed noting that there was nothing wrong with the car, such as flat tire or engine trouble, etc., that would justify investigation under the community caretaker doctrine. Ultimately, the Iowa Court of Appeals held that the State could not present evidence that a reasonable suspicion of criminal activity arose from the facts available to Officer Shutts. Consequently, the reasonable suspicion exception to the warrant requirement could not support the seizure of Elder's vehicle. State v. Elder, (Iowa Ct. App. 2015).