201533P.pdf   06/29/2021  United States  v.  Shaun Short
   U.S. Court of Appeals Case No:  20-1533
   U.S. District Court for the Southern District of Iowa - Central   
   [PUBLISHED] [Loken, Author, with Grasz and Kobes, Circuit Judges] 
   Criminal case - Criminal law and Sentencing. Even though defendant's 
   vehicle was temporarily immobilized by a flat tire, the officers 
   indisputably had probable cause to search the car, and an easily repaired 
   flat tire did not cause the vehicle to lose its inherent mobility; as a 
   result, the automobile exception applied, and the district court properly 
   denied defendant's motion to suppress evidence seized from the vehicle; 
   the district court did not err in refusing to hold a Franks hearing based 
   on defendant's allegations that the detective who completed the search 
   warrant application omitted key information; the district court did not 
   err in determining that defendant failed to establish the detective 
   deliberately or recklessly omitted information from the application; the 
   district court did not impose a substantively unreasonable sentence when 
   it imposed an upward variance based on the serious nature of the 
   underlying events.