State of Iowa v. Tyler Q. Chandler
16-1608
| Iowa Ct. App. | Nov 8, 2017Background
- Tyler Q. Chandler traveled from Indiana to Waterloo, Iowa, with three men (Jenkins, Hodges, Mathews) and stayed at Mathews’ apartment; the group was seen possessing two firearms and left together shortly before the Burger King robbery.
- On April 23, 2014, three masked, armed men entered a Burger King shortly before closing, assaulted employees, took cash drawers, and exited through the drive‑thru/emergency door; one employee was injured.
- Surveillance and scene evidence: a to‑go bag used earlier by Jenkins was found propping the drive‑thru door; DNA testing on leftover food in the bag matched Jenkins.
- Cell‑phone records showed texts from the phone registered to Chandler (used by Jenkins in the restaurant) relaying employee descriptions and advising when and which door to use; Chandler initially denied being in Iowa and lending his phone, later admitted he had been in Waterloo.
- Chandler was tried with Jenkins and Mathews, convicted of first‑degree robbery, and sentenced to 25 years (17.5 years mandatory minimum) to run consecutively to an Indiana sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence of Chandler’s participation | Circumstantial evidence (association with co‑defendants, cell‑phone use in furtherance of robbery, presence in Waterloo, matching firearms, post‑robbery disappearance, false statements) suffices to prove participation or aiding/abetting | No direct forensic or video ID; no witness identified Chandler; conviction rests on suspicion/speculation | Affirmed — circumstantial evidence sufficient to support conviction as principal or aider/abettor |
| Consecutive sentencing to Indiana term | Consecutive sentence appropriate given violent nature, multiple firearms, injury to victim, Chandler’s prior Indiana conviction for conspiracy to commit armed robbery | Argued court abused discretion; urged concurrent sentence based on youth, child support needs, minimal record, troubled upbringing, work history, and lower risk to reoffend; claimed court did not explain how consecutive terms served sentencing objectives | Affirmed — trial court provided adequate reasons (nature/circumstances, violence, prior serious conviction); no abuse of discretion |
Key Cases Cited
- Huser v. State, 894 N.W.2d 472 (Iowa 2017) (standard for reviewing sufficiency of evidence and weight of circumstantial proof)
- Hopkins v. State, 860 N.W.2d 550 (Iowa 2015) (abuse‑of‑discretion standard and presumption favoring sentencing court)
- Barnes v. State, 791 N.W.2d 817 (Iowa 2010) (requirement that sentencing court state reasons on the record for consecutive sentences)
