State v. Dillon Michael Heiller - Second-Degree Theft Jurisdiction Appeal
Summary
The Iowa Supreme Court reviewed a second-degree theft conviction in which defendant Dillon Michael Heiller challenged Iowa's territorial jurisdiction, arguing the vehicle theft occurred wholly in Wisconsin. The court affirmed the conviction, rejecting the jurisdiction argument. The court of appeals had previously affirmed on error preservation grounds. A dissent argued Iowa lacked territorial jurisdiction.
What changed
The Iowa Supreme Court affirmed a conviction for second-degree theft by taking a motor vehicle, rejecting the defendant's argument that Iowa lacked territorial jurisdiction because the theft occurred in Wisconsin. The court agreed with the reasoning in a companion case, State v. Heiller, No. 24-0169, and held that challenges to criminal jurisdiction cannot be raised for the first time on appeal. The dissent argued the State of Iowa lacked territorial jurisdiction to prosecute the taking of a vehicle from its owner in Wisconsin.
For criminal defendants and practitioners, this case reinforces Iowa's approach to preserving territorial jurisdiction challenges and establishes precedent for vehicle theft prosecutions involving multi-state conduct. Defense counsel should ensure jurisdictional objections are raised at trial, not on appeal.
Archived snapshot
Apr 18, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Case No. 24-0170
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.
County: Allamakee Trial Court Case No.: FECR015758
Resister
State of Iowa
Applicant
Dillon Michael Heiller
Attorney for the Resister
David Banta
Attorney for the Applicant
Shea M. Chapin
Supreme Court
Oral Argument Schedule
15-15-5
Feb 18, 2026 1:30 PM
Briefs
Appellant Reply Brief (118.89 KB)
Amicus Brief--ACLU of Iowa (372.68 KB)
Supreme Court Opinion
Opinion Number:
24-0170
Date Published:
Apr 17, 2026
PDF of the Opinion (166.68 KB)
Court of Appeals
Court of Appeals Opinion
Opinion Number:
24-0170
Date Published:
Sep 04, 2025
Summary
Appeal from the Iowa District Court for Allamakee County, John Bauercamper, Judge. AFFIRMED. Opinion considered without oral argument en banc. Opinion by Ahlers, J. Dissent by Tabor, C.J. (12 pages)
Dillon Heiller appeals his conviction for second-degree theft by raising a territorial-jurisdiction argument and challenging the sufficiency of the evidence supporting his conviction. OPINION HOLDS: We reject Heiller’s territorial-jurisdiction argument for the same reasons expressed in State v. Heiller, No. 24-0169. Heiller’s conviction is supported by substantial evidence. DISSENT ASSERTS: For the same reasons I explained in State v. Heiller, No. 24-0169, I would reverse Heiller’s conviction for second-degree theft because the State of Iowa lacked territorial jurisdiction to prosecute him for taking a vehicle from its owner in Wisconsin.
PDF of the Opinion (169.07 KB)
Other Information
Date Further Review is Granted:
Oct 30, 2025
Further Review Application (254.50 KB) View archived opinions from prior to November 2017
© 2026 Iowa Judicial Branch. All Rights Reserved.
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