State of Iowa v. Michael Leigh Schmidt
CourtCourt of Appeals of Iowa
Date FiledJune 24, 2026
Docket25-0456
StatusPublished
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Full Opinion
IN THE COURT OF APPEALS OF IOWA
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No. 25-0456
Filed June 24, 2026
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State of Iowa,
Plaintiff–Appellee,
v.
Michael Leigh Schmidt,
Defendant–Appellant.
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Appeal from the Iowa District Court for Scott County,
The Honorable Henry W. Latham II, Judge.
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AFFIRMED
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Martha J. Lucey, State Appellate Defender, and Allison Linafelter, Assistant
Appellate Defender, attorneys for appellant.
Brenna Bird, Attorney General, and Zachary Miller, Assistant Attorney
General, attorneys for appellee.
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Considered without oral argument
by Ahlers, P.J., Sandy, J., and Vogel, S.J.
Opinion by Ahlers, P.J.
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AHLERS, Presiding Judge.
After twelve pounds of methamphetamine were found in the rented
SUV Michael Schmidt was driving, a jury found him guilty of possession
with intent to distribute more than five kilograms of methamphetamine,
second offense. See Iowa Code §§ 124.401(1)(a)(7)(a), .411 (2024). The
district court sentenced him to serve a term of incarceration not to exceed
sixty years and pay a fine of $20,000.
Schmidt appeals. He contends (1) there is insufficient evidence that
he possessed the methamphetamine, and (2) the district court abused its
discretion by imposing a $20,000 fine.
As to the sufficiency-of-the-evidence challenge, we review for
correction of errors at law. State v. Brown, 32 N.W.3d 774, 778 (Iowa 2026).
We are bound by the jury’s verdict if it is supported by substantial evidence,
which is evidence sufficient to convince a rational fact finder that the
defendant is guilty beyond a reasonable doubt. Id. In assessing the
sufficiency of the evidence, we view it in the light most favorable to the State,
including drawing all legitimate inferences and presumptions that may be
fairly and reasonably deduced from it. Id.
Schmidt challenges the sufficiency of the evidence that he possessed
the methamphetamine found in the back of the SUV that he was driving
while his wife was a passenger. He contends the State failed to prove he had
the authority to exercise dominion and control over the drugs.
Possession can be actual or constructive. State v. Thomas, 847 N.W.2d
438, 442 (Iowa 2014). It requires proof that the defendant “exercised
dominion and control over the contraband.” Id. Actual possession is
established if the contraband is found on the defendant’s person or when the
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evidence establishes it was on the defendant’s person at one time. Id.
Constructive possession allows possession to be inferred based on the
contraband’s location and the surrounding circumstances. Id. at 443.
Dominion and control can be inferred if the defendant has exclusive control
of the location where the contraband is found. Id. But if multiple people are
in control of the location, dominion and control cannot be inferred. Id.
Because both Schmidt and his wife had control of the SUV in which
the drugs were found, there is no inference that Schmidt possessed the drugs
based on its presence in the SUV. But even without that inference, there is
sufficient evidence that Schmidt had actual and constructive possession of
the methamphetamine.
Viewing the evidence in the light most favorable to the State,
reasonable jurors could find the following facts. Schmidt and his wife were
known to be part of a drug operation that involved distributing large
quantities of methamphetamine from a distributor in Chicago. A text
message showed Schmidt and the distributor planning a drug transaction. A
few days before the events at issue, Schmidt, his wife, and her ex-husband
were involved in a group chat in which Schmidt talked about upcoming drug
transactions, including complaining about the quality of the drugs and saying
they needed to increase the quantity of drugs to meet the demand.
Then, on the day at issue, Schmidt’s wife drove from Des Moines to
Davenport. Law enforcement found the SUV Schmidt’s wife rented (the
same vehicle in which Schmidt, his wife, and the drugs were found later that
day) at a hotel in Davenport and followed the SUV to the area of Chicago
where the identified distributor lived. The SUV was driven by Schmidt’s
wife’s ex-husband. The ex-husband drove the SUV back to the hotel in
Davenport. Schmidt arrived a few minutes later in a rented van. Schmidt,
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his wife, and her ex-husband were seen together walking away from the two
vehicles. Schmidt then returned to the van, drove off in it, and took
countersurveillance measures before returning to the hotel. The three
people then got in the two vehicles and drove to a residential area where law
enforcement observed them moving items between the two vehicles. The ex-
husband drove off on a motorcycle, and Schmidt and his wife drove off in the
van and SUV. The three met up at a retail parking lot where officers again
observed items being moved between the SUV and the van. Schmidt then
drove the van to a vehicle-rental business while his wife followed in the SUV.
Schmidt returned the van, got in the driver’s side of the SUV while his wife
sat in the passenger seat, and drove off. When they stopped the vehicle at an
auto parts store, law enforcement surrounded the vehicle and detained
Schmidt and his wife.1 A drug dog alerted on the vehicle, and a subsequent
search revealed the twelve pounds of methamphetamine in a backpack in the
back of the SUV.
This evidence was sufficient to show that Schmidt knew the
methamphetamine was in the SUV and he exercised dominion and control
over it. His involvement in setting up the transaction and in moving items
between the van and the SUV would allow a reasonable fact finder to
conclude he had the drugs in his actual possession at some time that day and
that he had authority to exercise dominion and control over them. The
evidence also distinguishes Schmidt’s case from the cases upon which he
relies where evidence was found insufficient to establish authority to control
contraband. See, e.g., State v. Kern, 831 N.W.2d 149, 161–62 (Iowa 2013)
(finding inadequate proof of dominion and control based on the mere fact
that marijuana was being grown in a jointly occupied residence); State v. Bash,
1
Schmidt did not have a driver’s license.
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670 N.W.2d 135, 136–39 (Iowa 2003) (finding insufficient proof of authority
to exercise control of drugs found in a box on the defendant’s husband’s side
of the bed in a jointly occupied residence); State v. Webb, 648 N.W.2d 72, 79–
80 (Iowa 2002) (finding insufficient evidence of control over drugs found in
jointly occupied residence when defendant was not on premises when search
occurred, there was no evidence of when he had last been there, the drugs
were not found in locations exclusively accessible to the defendant, and the
drugs were not found near the defendant’s personal belongings); State v.
Atkinson, 620 N.W.2d 1, 4–5 (Iowa 2000) (finding that, even though
defendant knew there were drugs in her companion’s fanny pack, there was
insufficient evidence defendant had the right to exercise control over the
fanny pack).
Because there was sufficient evidence to support the jury’s finding that
Schmidt had the authority to exercise dominion and control over the
methamphetamine found in the SUV, his sufficiency-of-the-evidence
challenge fails.
As to Schmidt’s challenge to the fine imposed, because the fine is
within statutory limits, we review for an abuse of discretion. See State v.
Majors, 940 N.W.2d 372, 385 (Iowa 2020). Schmidt contends the district
court erred in choosing a fine of $20,000 because the court did not give an
explanation for that fine amount. But the court did give an explanation:
Mr. Schmidt, it’s my duty to determine what the appropriate
rehabilitative plan would be for you. I have to look at the very serious
nature of the offense that you have been convicted of, the impact that it’s
had on the community, and how the community must be protected from
this type of criminal behavior. I have to look at the least restrictive
alternatives and proceed to the more restrictive alternatives.
I have reviewed your entire presentence investigation report for the
purposes of today’s sentencing, but I have not considered any of the entries
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in the criminal history section that do not reflect an admission of guilt or a
finding of guilt in regards to those offenses.
After going on to discuss how Schmidt’s criminal conduct endangered
himself and others, the court then imposed a $20,000 fine, stating, “I believe
the fine is appropriate based on the amount of methamphetamine.”
Schmidt’s only challenge to the imposition of the fine is that the court
did not give a reason for the amount of the fine. But the court did give a
reason, so his challenge fails.
AFFIRMED.
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