In re the Detention of Sanders

CourtCourt of Appeals of Iowa
DecidedApril 1, 2026
Docket24-2006
StatusPublished

This text of In re the Detention of Sanders (In re the Detention of Sanders) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re the Detention of Sanders, (iowactapp 2026).

Opinion

IN THE COURT OF APPEALS OF IOWA _______________

No. 24-2006 Filed April 1, 2026 _______________

In re Detention of Dylan Larence Sanders,

Dylan Larence Sanders, Respondent–Appellant. _______________

Appeal from Iowa District Court for Pottawattamie County, The Honorable Craig M. Dreismeier, Judge. _______________

AFFIRMED _______________

Wendy S. Samuelson, Assistant State Public Defender, Special Defense Unit, Des Moines, attorney for appellant.

Brenna Bird, Attorney General, Anagha Dixit (until withdrawal) and Nicholas E. Siefert, Assistant Attorneys General, attorneys for appellee. _______________

Considered without oral argument by Tabor, C.J., and Badding and Sandy, JJ. Opinion by Badding, J.

1 BADDING, Judge.

When explaining why he committed a sexually violent offense against a twelve-year-old girl, Dylan Sanders said, “At the time I just wanted to do what I wanted to do.” Sanders was diagnosed by two licensed psychologists with impulse control and conduct disorder. Although the psychologists agreed on Sanders’ diagnosis, they disagreed on whether he met the criteria for commitment as a sexually violent predator under Iowa Code chapter 229A (2023). Faced with these conflicting opinions, the district court found the State’s expert was more convincing and granted the committal petition.

On appeal from that judgment, Sanders challenges the sufficiency of the evidence supporting the district court’s determination that he is a sexually violent predator. Deferring to the court’s choice between the competing expert opinions, we affirm.

I. Background Facts and Proceedings

In the fall of 2017—over the course of one week—Sanders had sexual contact with three female minors: R.B., C.H., and S.B. Two of the children were eleven years old; the other was twelve. Sanders was twenty-one. He was convicted of third-degree sexual assault on a child for an offense that occurred in Nebraska and two counts of lascivious acts with a child for the offenses in Iowa. Sanders was sentenced to prison in 2019.

While serving that sentence, Sanders had five to ten sexual partners and engaged in at least twenty consensual sexual encounters with them. He was disciplined for several of these encounters because the prison prohibited sexual contact between inmates. Sanders also had a substantiated complaint under the Prison Rape Elimination Act for “sexually licking his lips” toward another inmate and telling him, “I’ll knock you out and suck you off.”

2 Sanders’ first attempt at sex offender treatment was in November 2021. He was removed from the program three months later after he had his cellmate touch his genitals. He restarted the program in August 2022 and completed it in January 2023. During the treatment, Sanders disclosed a sexual history dating back to when he was ten years old and continuing through his incarceration at age twenty-one that included sexual activity with animals and other minor victims—male and female.

In December 2023, as Sanders’ discharge date approached, the State filed a petition to have him confined as a sexually violent predator under Iowa Code chapter 229A. At a bench trial the next year, each side presented evidence from licensed psychologists with experience in evaluating sexually violent predators. The State called Dr. William Schmitt, while Sanders called Dr. Luis Rosell. Dr. Schmitt diagnosed Sanders with “other specified disruptive, impulse-control, and conduct disorder,” which is characterized by “problems in the self-control of emotions and behaviors.” Dr. Rosell agreed with that diagnosis. But from there, the experts parted ways. Dr. Schmitt testified that Sanders had a mental abnormality that made him “more likely than not to commit a sexual violence in the future.” Dr. Rosell disagreed, focusing on Sanders’ more recent behavior and response to sex offender treatment. He also challenged Dr. Schmitt’s risk assessment methodology.

After considering all the evidence, the district court agreed with Dr. Schmitt’s opinion and found the State had proven beyond a reasonable doubt that Sanders was a sexually violent predator. The court granted the State’s petition and ordered Sanders to be committed under Iowa Code section 229A.7(5)(b). Sanders appeals, challenging the sufficiency of the evidence supporting that decision.

3 II. Standard of Review

We review challenges to the sufficiency of the evidence for the correction of errors at law. In re Det. of Swanson, 668 N.W.2d 570, 574 (Iowa 2003). The district court’s findings are binding on us if they are supported by substantial evidence upon which a “rational trier of fact could conceivably find the defendant is a sexually violent predator beyond a reasonable doubt.” To determine whether the evidence was substantial, we consider the entirety of the evidence presented in a “light most favorable to the State, including all legitimate inferences and presumptions which may be fairly and reasonably deduced from the record.” Evidence is not substantial if it raises only suspicion, speculation, or conjecture.

Id. (cleaned up).

III. Analysis

To succeed on its petition to civilly commit Sanders, the State was required to prove beyond a reasonable doubt that he is a sexually violent predator. Iowa Code § 229A.7(5); In re Det. of Pierce, 748 N.W.2d 509, 512 (Iowa 2008). A person is a sexually violent predator if the person (1) “has been convicted of a sexually violent offense”; (2) “suffers from a mental abnormality”; and (3) the mental abnormality makes the person “more likely than not to engage in predatory acts constituting sexually violent offenses, if not confined in a secure facility.” Pierce, 748 N.W.2d at 512; see also Iowa Code § 229A.2(15) (defining “sexually violent predator”). Sanders contests the State’s proof of the second and third elements.

For the second element, Iowa Code section 229A.2(8) defines a “mental abnormality” as “a congenital or acquired condition affecting the emotional or volitional capacity of a person and predisposing that person to commit sexually violent offenses to a degree which would constitute a

4 menace to the health and safety of others.” “To prove such a condition exists, the State must show the respondent has ʻa serious difficulty in controlling behavior.’” In re Det. of McFadden, No. 23-1935, 2024 WL 5153703, at *2 (Iowa Ct. App. Dec. 18, 2024) (quoting In re Det. of Barnes, 658 N.W.2d 98, 101 (Iowa 2003)).

Relying on his expert’s opinion, Sanders claims that his condition did not affect his volitional capacity because “he had no other record of criminal offenses other than his sex offenses” and because he “did not act out in a violent manner in prison.” Sanders points to Dr. Rosell’s testimony that although Sanders had “problematic behavior” in the past, the behavior did not continue in prison, where “he basically interacted with males in a consensual manner.”

Dr. Schmitt disagreed. He testified that Sanders has “had a problem controlling his impulses over the years. That’s primarily come out in terms of his sexual offending in the community as well as his sexual activity in prison.” Even though Sanders’ sexual activity in prison was consensual, Dr. Schmitt stated “it’s still breaking the rules. So that’s how I still see it as a problem with him controlling his impulses.” Dr.

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Related

In Re Detention of Barnes
658 N.W.2d 98 (Supreme Court of Iowa, 2003)
In Re Detention of Swanson
668 N.W.2d 570 (Supreme Court of Iowa, 2003)
In Re Detention of Willis
691 N.W.2d 726 (Supreme Court of Iowa, 2005)
In Re Detention of Barnes
689 N.W.2d 455 (Supreme Court of Iowa, 2004)
In Re the Detention of Pierce
748 N.W.2d 509 (Supreme Court of Iowa, 2008)

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In re the Detention of Sanders, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-detention-of-sanders-iowactapp-2026.