State of Iowa v. Dillon Michael Heiller

Defendant appealed his conviction for second-degree theft by taking of a motor vehicle. He argued that the state lacked criminal jurisdiction to prosecute him for the offense because the evidence showed that the theft occurred wholly outside the state. The court of appeals rejected the defendant’s argument on error preservation grounds and affirmed, holding that challenges to criminal jurisdiction cannot be raised for the first time on appeal. Defendant seeks further review.

Holding: The defendant appeals his conviction for theft by taking of a vehicle that was reported stolen in Wisconsin, arguing that the State of Iowa lacked criminal jurisdiction to prosecute him for the offense. Decision of Court of Appeals Vacated; District Court Conviction and Sentence Vacated and Case Remanded.