State of Iowa v. Anthony Frank Ernst, 954 N.W.2d 50

On August 21, 2017 the service door of a garage belonging to a parole officer and her husband was found ajar with damage consistent with prying; nothing was taken.
Surveillance from a business near the home showed a single unaccounted-for white Crown Victoria (distinct chipped-paint pattern) drive down the dead-end road at 10:31 a.m. and return ~13 minutes later.
The parole officer identified the vehicle as belonging to Anthony Ernst; video showed a driver wearing clothing similar to what Ernst later wore that day.
Evidence established Ernst was in the general area that morning, had reason to know the homeowners would be away, and had previously obtained the parole officer’s address; Ernst offered family alibi testimony that conflicted with surveillance and traffic-camera records.
Ernst was charged with third-degree burglary (assault and theft theories); the district court dismissed the assault theory but submitted attempted burglary with intent to commit theft to the jury, which convicted Ernst and sentenced him to two years.
The court of appeals reversed, finding the conviction rested on impermissible "stacking of inferences;" the Iowa Supreme Court granted further review and affirmed the conviction.

Issue	State's Argument	Ernst's Argument	Held
Sufficiency: identity and attempted entry	Circumstantial evidence (surveillance, vehicle ID, pry marks, timing) supports inference Ernst was the actor and attempted entry	Video shows only presence in area; evidence is speculative and insufficient	Conviction affirmed; evidence and reasonable inferences suffice to identify Ernst and support attempted entry
Sufficiency: specific intent to steal	Surreptitious forced entry, timing when homeowners were away, Ernst’s knowledge of address, implausible alibis permit inference of intent to steal	Intent cannot be inferred by stacking inferences; circumstantial proof is speculative	Affirmed; intent may be inferred from the totality of circumstantial evidence and is not defeated by stacked-inference argument
Stacking of inferences doctrine	Stacking of inferences is not categorically prohibited; courts review whether inferences are reasonable or speculative	Court of appeals erred by reversing for stacking inferences	Affirmed; stacking permitted so long as ultimate inference reasonably flows from record and is not speculative
Ineffective assistance (failure to object to cell-tower testimony/records)	Admission may have been proper or an expert could be qualified; record underdeveloped	Trial counsel ineffective for not objecting to cell-site testimony and phone records hearsay	Claim preserved for postconviction relief to develop a fuller record; not resolved on direct appeal

State v. Kelso-Christy, 911 N.W.2d 663 (Iowa 2018) (standard for reviewing sufficiency of the evidence)
State v. Tipton, 897 N.W.2d 653 (Iowa 2017) (legitimate inferences from record evidence considered on sufficiency review)
State v. O'Connell, 275 N.W.2d 197 (Iowa 1979) (abolished the rigid direct-vs-circumstantial-evidence distinction)
State v. Truesdell, 679 N.W.2d 611 (Iowa 2004) (single-piece-of-evidence inference discussed; limited to that context)
State v. Keeton, 710 N.W.2d 531 (Iowa 2006) (distinguishing Truesdell where multiple items of evidence collectively support intent)
State v. Bentley, 757 N.W.2d 257 (Iowa 2008) (State not required to disprove every hypothesis favorable to defendant)
State v. Sangster, 299 N.W.2d 661 (Iowa 1980) (intent to steal may be inferred from surreptitious entry)
State v. Erving, 346 N.W.2d 833 (Iowa 1984) (breaking and entry into a place containing valuables supports inference of intent to steal)
State v. Boothby, 951 N.W.2d 859 (Iowa 2020) (lay vs. expert testimony on historical cell-site data depends on underlying information)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (appellate courts must defer to jury’s resolution of conflicting inferences when supported by substantial evidence)