State v Heiller - Theft Convictions Appeal

Iowa Supreme Court

Filed March 20th, 2026

Detected March 21st, 2026

Summary

The Iowa Supreme Court issued an opinion in State v. Heiller, addressing appeals related to theft convictions. The court affirmed the convictions, finding sufficient evidence for taking and intent, and that territorial jurisdiction was not preserved as a sufficiency issue. The decision clarifies the handling of territorial jurisdiction claims and jury instructions in criminal appeals.

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What changed

The Iowa Supreme Court has issued its opinion in State v. Heiller (Case No. 24-0169), affirming the theft convictions of Dillon Michael Heiller. The appeal concerned the sufficiency of evidence for theft by taking and the State's territorial jurisdiction for one of the charges. The court held that Heiller failed to preserve error on his territorial jurisdiction challenge as a sufficiency issue, as it was primarily raised as an attack on the jury instructions. The court also found substantial evidence supporting the jury's guilty verdicts for the taking and intent elements on both charges.

This ruling has implications for how criminal defendants can challenge territorial jurisdiction and sufficiency of evidence claims in Iowa. Compliance officers and legal professionals should note that failure to object to jury instructions or raise constitutional claims at the trial court level can result in a waiver of those arguments on appeal. The decision underscores the importance of proper preservation of error for all grounds of appeal, particularly in cases involving complex evidentiary and jurisdictional questions. The court's affirmation of the convictions means the defendant will proceed with the consequences of his guilty verdicts.

What to do next

Review court opinion for implications on evidence sufficiency and territorial jurisdiction arguments.
Ensure proper preservation of error for all appellate challenges in criminal cases.

Source document (simplified)

Main Content

Case No. 24-0169

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.

County: Allamakee Trial Court Case No.: FECR015756

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 Brief (312.83 KB)

Appellee Brief (412.72 KB)

Appellant Reply Brief (123.68 KB)

Amicus Brief--ACLU of Iowa (372.68 KB)

Supreme Court Opinion

Opinion Number:

24-0169

Date Published:

Mar 20, 2026

PDF of the Opinion (136.89 KB)

Court of Appeals

Court of Appeals Opinion

Opinion Number:

24-0169

Date Published:

Sep 04, 2025

Summary

Appeal from the Iowa District Court for Allamakee County, John Bauercamper, Judge. AFFIRMED. Considered without oral argument en banc. Opinion by Ahlers, J. Partial Dissent by Tabor, C.J. (20 pages)

Dillon Heiller appeals from his convictions for first-degree theft and second-degree theft for the taking of two separate vehicles. He contends the evidence is insufficient to establish territorial jurisdiction on one charge and is insufficient as to the taking and intent elements on both charges. OPINION HOLDS: Heiller’s territorial-jurisdiction argument is not a sufficiency challenge. Instead, it is an attack on the marshaling instruction for failure to include a territorial-jurisdiction element. But Heiller did not object to the instruction, so he failed to preserve error on that claim. To the extent that he intends to raise a constitutional challenge, he failed to preserve error by raising that claim in the district court. To the extent that Heiller argues that territorial jurisdiction is an issue of subject matter jurisdiction, we disagree. As to his challenge to the sufficiency of the evidence on the taking and intent elements of both charges, we find substantial evidence supporting the jury’s guilty verdicts. PARTIAL DISSENT ASSERTS: The majority’s approach disregards a clear statement of law that is binding on our court and anchors its analysis to Heiller’s jury instruction claim without addressing the sufficiency-of-the-evidence claim. Territorial jurisdiction is an essential element of the offense, and the State failed to offer substantial evidence to show any element took place in Iowa. Under our precedents, I would reverse Heiller’s second-degree theft conviction and remand for dismissal.

PDF of the Opinion (206.47 KB)