State of Iowa v. Dillon Michael Heiller

── State of Iowa v. Dillon Michael Heiller ── Court: Supreme Court of Iowa Date: April 17, 2026 Category: General In the Iowa Supreme Court No. 24–0170 Submitted February 18, 2026—Filed April 17, 2026 State of Iowa, Appellee, vs. Dillon Michael Heiller, Appellant. On review from the Iowa Court of Appeals. Appeal from the Iowa District Court for Allamakee County, John Bauercamper, senior judge. 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. McDonald, J., delivered the opinion of the court, in which all justices joined. Shea M. Chapin (argued) of The Chapin Center, PLC, Dubuque, for appellant. Brenna Bird, Attorney General, and Martha E. Trout (argued), Assistant Attorney General, for appellee. Jacob A. Sarasin, Thomas D. Story, Shefali Aurora, and Rita Bettis Austen of ACLU of Iowa Foundation Inc., Des Moines, for amicus curiae American Civil Liberties Union of Iowa.  2 McDonald, Justice. This case involves a challenge to the State of Iowa’s attempted exercise of its criminal jurisdiction. A vehicle was reported stolen in La Crosse, Wisconsin. The next day, only a short distance away in Waukon, Iowa, police officers found Dillon Heiller in possession of that same vehicle and placed him under arrest. Heiller was charged with and convicted of theft under a theory of theft by taking. Heiller did not challenge the State’s assertion of criminal jurisdiction in the district court, but he challenges it for the first time on appeal. Iowa’s criminal jurisdiction statute, Iowa Code section 803.1 (2023), provides that a person is “subject to prosecution in this state” only under certain conditions. Satisfaction of those conditions is a necessary, nonwaivable prerequisite to any criminal prosecution, and a party can raise a challenge to the State’s criminal jurisdiction at any time during the pendency of the case, even on appeal. On the merits, we conclude that the statutory conditions necessary to invoke the State’s power to prosecute Heiller for this offense were not satisfied and that his conviction must be vacated. I. At approximately 7:30 in the morning on October 1, 2023, Heiller parked an orange 2018 Volkswagen Tiguan SUV bearing Wisconsin license plates in front of a house in Waukon, Iowa. One of the homeowners was on her porch having a cup of coffee. She did not recognize Heiller or the vehicle. She went inside the house and watched Heiller from the mudroom. Heiller exited the vehicle and went back and forth from the trunk to the front seat. Then he went into the backseat of the vehicle and closed the doors. The homeowner thought that was odd, and she called her husband to come and watch. Heiller got out of the vehicle, opened the trunk, and placed items into a backpack. He put up the  3 hood on his orange sweatshirt and put on sunglasses. Then he walked a block or so away carrying the backpack and a four-pack of wine coolers. The woman thought “it was really weird” that Heiller would park one block away from the person he was visiting, and she called the Waukon Police Department. She gave the police department the license plate information. The police department ran the plate, told the woman that the car was reported stolen, and told her that they would be there in a minute. Officer Brent Parker received the call from the homeowner. After running the license plate check, Parker went to the house to inve