State of Iowa v. Abraham Riko, 20-1739

On July 11, 2019 the victim left home at noon and returned about 10:00 p.m. to find the residence ransacked and several items missing (an antique shotgun, jewelry, a change jar).
Neighbors reported seeing a white female in a black hoodie in the area; no eyewitness tied Riko to the break-in.
Crime scene personnel lifted ten latent prints from the home; five were insufficient, five were entered into ABIS, yielding matches for the victim and three prints matching Abraham Riko on items (power adapter box and a streaming-device manual) located near a rifled TV console.
Photographs and testimony placed the items bearing Riko’s prints in an area the victim had identified as disturbed; the jury could infer those items had been removed from a partially open cabinet and searched for valuables.
Riko was tried for third-degree burglary (as a habitual offender); the trial court denied his motion for acquittal arguing insufficient evidence of specific intent to steal, the jury convicted him of third-degree burglary, and he appealed on sufficiency-of-the-evidence grounds.

Issue	State's Argument	Riko's Argument	Held
Whether there was sufficient evidence that Riko acted with the specific intent to commit a theft (element of third-degree burglary)	The presence of Riko’s fingerprints on items disturbed during a ransacking, combined with the obvious foraging of the home and missing property, permits a rational jury to infer he intended to steal.	Fingerprint matches only prove presence at some time, not intent to steal; alternative explanations (other suspects, lack of forced entry, unidentified prints) create reasonable doubt.	Affirmed. Viewing evidence in the light most favorable to the State, the circumstantial evidence (ransacking, missing items, Riko’s prints on disturbed items) was sufficient for a rational jury to infer specific intent to steal.

State v. Albright, 925 N.W.2d 144 (Iowa 2019) (standard for appellate sufficiency review)
State v. Ortiz, 905 N.W.2d 174 (Iowa 2017) (view evidence in light most favorable to State and draw reasonable inferences)
State v. Huser, 894 N.W.2d 472 (Iowa 2017) (consider all evidence, not only inculpatory)
State v. Wickes, 910 N.W.2d 554 (Iowa 2018) (definition of substantial evidence)
State v. Ramirez, 895 N.W.2d 884 (Iowa 2017) (substantial-evidence standard quotation)
State v. Musser, 721 N.W.2d 758 (Iowa 2006) (appellate court does not weigh credibility or resolve conflicts)
State v. Williams, 695 N.W.2d 23 (Iowa 2005) (same principle on credibility and fact finding)
State v. Ernst, 954 N.W.2d 50 (Iowa 2021) (presence plus other evidence can support guilt)
State v. Schrier, 300 N.W.2d 305 (Iowa 1981) (mere presence alone ordinarily insufficient)
State v. Banes, 910 N.W.2d 634 (Iowa Ct. App. 2018) (unchallenged jury instructions serve as law of the case)