Antonio Clarence Robertson was sentenced to 48 months in prison after pleading guilty to possession with intent to distribute controlled substances, but reserved his right to appeal the district court's denial of his motion to suppress evidence obtained during a traffic stop.
Cedar Rapids police officers were patrolling near Jim's Foods on December 21, 2023, when they observed suspicious activity involving hand-to-hand transactions near a Chevrolet Cruz. When the vehicle exited the parking lot without coming to a complete stop before entering the roadway, officers initiated a traffic stop for violating Iowa Code Section 321.353.
During a consensual search of the vehicle, officers found prescription pills in Robertson's seat and a bag of the same pills in his pocket, along with marijuana concealed on his person.
Robertson argued that the Jim's Foods parking lot should be considered a public roadway rather than a private driveway, which would exempt it from the stopping requirement. The Eighth Circuit rejected this argument, citing Iowa Supreme Court precedent that parking lots for private businesses remain private driveways despite being open to customers.
The court distinguished between implied permission for the public to use a lot for business purposes and the public having 'a matter of right' access for vehicular traffic, emphasizing that private owners maintained control over the lot and could tow vehicles or restrict access.
Writing for the panel, Circuit Judge Benton noted that Iowa law clearly defines such business parking lots as private driveways, not public highways, and that the officers had an objectively reasonable basis for believing a traffic violation had occurred.