State of Iowa v. Dillon Michael Heiller

The State charged Dillon Heiller with three counts of theft for stealing three vehicles. The State prosecuted each count on a theft by taking theory, and Heiller was convicted of two of the three counts. On appeal, Heiller argued that the evidence was insufficient to support either conviction because there was no evidence that he actually took the vehicles, as opposed to merely possessing them. As to one theft, Heiller argued that the State lacked territorial jurisdiction to prosecute him because the evidence showed that the crime occurred wholly outside the state of Iowa. The court of appeals held that the evidence was sufficient and that Heiller did not preserve error on his territorial jurisdiction challenge. Heiller sought further review.

Holding: The defendant appeals two theft convictions, arguing that the evidence was insufficient to support the jury’s verdict. Decision of Court of Appeals Vacated; District Court Judgment Affirmed in Part, Reversed in Part, and Case Remanded.