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