State of Iowa v. Charles Lee Schrage, 15-1094

Police converged on the Schrage residence to execute an arrest warrant for Dennis; Charles was present and walked toward Dennis as officers approached.
An officer observed Charles reach toward Dennis; Dennis then appeared to cup something and place it under the deck of a riding lawn mower in one quick motion.
Officers found a brass pipe, a prescription bottle with marijuana, and a small container with methamphetamine under the mower; items appeared recently placed.
Charles said he had been handing Dennis his phone; both men retained their cell phones. Dennis later wrote he would take blame for the drugs and suggested a different story about the phone.
A jury convicted Charles of possession of methamphetamine and possession of marijuana; at sentencing the court imposed concurrent prison terms, rejecting a recommendation of suspension because Charles had a lengthy criminal history and would not accept responsibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove possession (actual or constructive)	State: Circumstantial evidence showed Charles had dominion/control — he approached Dennis, made a hand-to-hand transfer, then Dennis hid the drugs; Charles acted to rid himself of the drugs and gave inconsistent explanations.	Charles: No proof he had actual or constructive possession — officers did not see the item, no fingerprints, Dennis claimed sole responsibility.	Court: Affirmed. Substantial evidence supports conviction; jury could infer Charles handed drugs to Dennis to discard when police approached and discount Dennis’s explanation.
Adequacy of sentencing statement under Iowa R. Crim. P. 2.23(3)(d)	State: Court’s brief reasons (criminal history, failure to accept responsibility, prior prison/probation failures) justify incarceration.	Charles: Judge’s reasons were too terse to permit meaningful appellate review.	Court: Affirmed. Succinct statement was sufficient; no abuse of discretion.

Rohm v. State, 609 N.W.2d 504 (Iowa 2000) (standard for reviewing sufficiency of the evidence)
Kern v. State, 831 N.W.2d 149 (Iowa 2013) (possession defined as dominion and control; actual vs constructive possession)
Thomas v. State, 847 N.W.2d 438 (Iowa 2014) (constructive-possession when items found near defendant and additional linking evidence required)
Vance v. State, 790 N.W.2d 775 (Iowa 2010) (actual possession may be proved circumstantially)
Cashen v. State, 666 N.W.2d 566 (Iowa 2003) (types of additional evidence to link defendant to drugs)
Dewitt v. State, 811 N.W.2d 460 (Iowa 2012) (flight or evasive conduct as evidence consistent with guilt)
Blair v. State, 347 N.W.2d 416 (Iowa 1984) (role of jury in assessing witness credibility)
Barnes v. State, 791 N.W.2d 817 (Iowa 2010) (sentencing rule requires at least a cursory explanation)
Hennings v. State, 791 N.W.2d 828 (Iowa 2010) (standard of review for sentencing)
Carberry v. State, 501 N.W.2d 473 (Iowa 1993) (upholding sentences despite terse statements)
Victor v. State, 310 N.W.2d 201 (Iowa 1981) (brief statement may suffice when reasons for sentence are clear)
Russian v. State, 441 N.W.2d 374 (Iowa 1989) (court not required to list all mitigating circumstances)