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State of Iowa v. Drew Alan Mangler
19-0469
Iowa Ct. App.
Nov 4, 2020
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Background

  • Victim James Remakel was found dead in his Bellevue, Iowa home on December 25, 2016 with 32 stab wounds; medical evidence placed death on December 19–20, 2016.
  • Investigators found blood throughout the house, forced-open dresser drawers with cash and prescriptions, and 26 footwear impressions; all DNA from the home matched the victim.
  • Drew Mangler was in Bellevue alone the night of December 19, walked within five–six blocks of Remakel’s home, and later exhibited a sudden influx of cash which he spent the next day.
  • Forensic comparison identified several footwear impressions that could have been made by Mangler’s shoes; Remakel’s blood was detected on the tongue of Mangler’s right shoe.
  • A jury convicted Mangler of second-degree murder; he appealed, raising sufficiency of evidence, a jury-instruction challenge, exclusion of a voicemail mentioning “manslaughter,” and a Brady/new‑trial claim.

Issues

Issue State's Argument Mangler's Argument Held
Sufficiency of the evidence Evidence (blood on shoe, footwear matches, opportunity, motive, cash spending) permits conviction No direct link to killing; shoe match not unique; other witnesses saw nothing Affirmed—substantial circumstantial evidence supports verdict
Jury instruction (No. 29) Instruction correctly applied law; malice instruction also given Instruction conflated general intent with malice and was confusing Error not preserved; alternatively no Strickland prejudice—no relief
Exclusion of voicemail saying “manslaughter” Exclusion proper under trial court’s Rule 5.403 balancing Voicemail was admissible and could point to alternative suspect Affirmed—trial court did not abuse discretion excluding the voicemail
Brady / new trial re: witness sighting Rogge No suppression/materiality; sighting was cumulative/common‑knowledge and could have been discovered by defense State failed to disclose exculpatory info that Rogge was near victim’s home Affirmed—no Brady violation and evidence not material to likely outcome

Key Cases Cited

  • Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose favorable, material evidence)
  • Strickland v. Washington, 466 U.S. 668 (1984) (two‑part ineffective assistance standard)
  • State v. Meyers, 799 N.W.2d 132 (Iowa 2011) (substantial‑evidence standard for sufficiency review)
  • State v. Kelso‑Christy, 911 N.W.2d 663 (Iowa 2018) (no distinction between direct and circumstantial evidence)
  • State v. Einfeldt, 914 N.W.2d 773 (Iowa 2018) (trial court discretion under evidentiary balancing Rule 5.403)
  • State v. Buenaventura, 660 N.W.2d 38 (Iowa 2003) (definition of malice aforethought)
Read the full case

Case Details

Case Name: State of Iowa v. Drew Alan Mangler
Court Name: Court of Appeals of Iowa
Date Published: Nov 4, 2020
Docket Number: 19-0469
Court Abbreviation: Iowa Ct. App.