State of Iowa v. Randy Lee Patrie

• Court: Court of Appeals of Iowa
• Decided: December 3, 2025
• Docket: 24-1107
• Status: Published

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 24-1107 Filed December 3, 2025

STATE OF IOWA, Plaintiff-Appellee,

vs.

RANDY LEE PATRIE, Defendant-Appellant. ________________________________________________________________

Appeal from the Iowa District Court for Chickasaw County,

Richard D. Stochl, Judge.

A criminal defendant appeals his conviction for first-degree murder.

AFFIRMED.

Martha J. Lucey, State Appellate Defender, and Maria Ruhtenberg (until

withdrawal) and Josh Irwin, Assistant Appellate Defenders, for appellant.

Brenna Bird, Attorney General, and Zachary Miller, Assistant Attorney

General, for appellee.

Considered without oral argument by Schumacher, P.J., Sandy, J., and

Telleen, S.J.*

*Senior judge assigned by order pursuant to Iowa Code section 602.9206

(2025). 2

TELLEEN, Senior Judge.

Following a jury trial, Randy Lee Patrie was convicted of first-degree

murder. The State presented evidence that Patrie used a sawed-off shotgun to

shoot the victim, a retired grocery store owner, in the right temple at point-blank

range. Patrie appeals his conviction, arguing that the State presented insufficient

evidence of his guilt. Because the evidence of Patrie’s guilt is overwhelming, we

affirm.

I. Background Facts and Proceedings

The victim of the murder was a retired grocery store owner who lived alone

in a home out in the country in Nashua, Iowa. The last date anyone saw the victim

alive was on the afternoon of September 25, 2012. On October 2, a friend showed

up to the victim’s home to request permission to hunt on the victim’s property. The

friend regularly hunted there but still sought official permission from the victim. The

victim did not answer the door that day and his phone line was busy. The friend

returned two days later after noticing “the bird feeders were all empty and the

birdbaths were empty.” The victim still did not answer the door despite his truck

being parked at the home. The friend noticed that the victim’s mailbox was full and

looked through the front window and observed that the interior of the home was

ransacked; “[t]he refrigerator was tipped over and the cushions were thrown on the

floor and the pictures were thrown off the wall,” despite the victim normally keeping

an “immaculate” home.

The friend reported the suspicious circumstances to law enforcement who

then came out to the victim’s house to conduct a welfare check. Upon entering the

home and after walking into the victim’s bedroom, the deputy found the victim’s 3

body lying in his bed covered by a bookshelf, books, video tapes, and other debris.

The victim had a gunshot wound to the head. Law enforcement confirmed that the

home was ransacked and items were missing, including a television, night vision

scope, decoy security camera, some power tools, and three guns. A garage door

opener was missing from the victim’s truck. Law enforcement opined that it would

have been difficult to enter the home other than through the garage door due to

metal and wood bars holding the doors shut and one garage door being held shut

with a metal clamp. The missing items were not reported to the press.

The medical examiner determined the cause of death was a shotgun blast

to the right temple, fired at a range of approximately a few inches from the victim’s

head, due to the wad cup being found inside the victim’s head. A ballistics expert

testified that, due to the scratch patterns on the wad, the shot had been fired by a

sawed-off .410 shotgun.

The investigation did not yield immediate results but in July 2013, law

enforcement searched Patrie’s home for unrelated reasons. Power tools, a decoy

security camera, a night vision scope, and a police scanner consistent with those

missing from the victim’s home were found. A television was found that matched

the serial number of the missing television from the victim’s home. Three firearms

of the exact same make and model as the firearms missing from the victim’s home

were found—two of which were stuffed into the insulation of Patrie’s attic. A

sawed-off .410 shotgun was also found in the home. Patrie, unprompted and

before being asked about any guns, told an Iowa Division of Criminal Investigation

(DCI) special agent, “I’m not going to give you the name of the guy that I got these

guns from. I didn’t steal these fucking guns.” The individuals Patrie claimed to 4

have acquired the weapons from either had alibis for the date of the murder or

were deceased. Patrie admitted to “falsely accus[ing]” one of the individuals with

an alibi of giving him one of the guns. He claimed to not know where the victim

lived.

Several years later, the defendant revised his story as to what happened

the night of September 25 and the morning of September 26. He claimed that he

was home that night to consume methamphetamine and his uncle came to the

house at 3:00 a.m. to borrow his car and returned it later that day. Because Patrie’s

uncle had the car, Patrie claimed he called in sick for work at 7:00 a.m. According

to Patrie, his uncle called him after Patrie had called in sick for work and gave him

all the stolen property in the vehicle. Phone records revealed that Patrie did not

call his employer at 7:00 a.m. as he claimed and that he never received a phone

call from his uncle.

The State charged Patrie with first-degree murder in January 2022, and the

jury returned a verdict convicting him as charged. Patrie moved for new trial and

in arrest of judgment, challenging sufficiency and weight of the evidence and

alleging that Patrie was deprived of due process. The district court denied Patrie’s

motion. Patrie now appeals.

II. Standard of Review

We review challenges to the sufficiency of evidence for corrections of legal

error. State v. Sanford, 814 N.W.2d 611, 615 (Iowa 2012). We will uphold the

verdict if it is supported by substantial evidence. Id. Substantial evidence is

evidence that, “when viewed in the light most favorable to the State,” could

convince a rational factfinder of Patrie’s guilt beyond a reasonable doubt. Id. We 5

recognize that “the jury is free to reject certain evidence, and credit other

evidence.” Id. (cleaned up).

III. Discussion

It is the State’s burden to prove every element of the crime charged. State

v. Armstrong, 787 N.W.2d 472, 475 (Iowa Ct. App. 2010). The jury was instructed

that the State had to prove the following elements:

1. On or between September 25, 2012, through October 4, 2012, [Patrie] shot [the victim]. 2. [The victim] died as a result of being shot. 3. [Patrie] acted with malice aforethought. 4. [Patrie] acted willfully, deliberately, premeditatedly and with the specific intent to kill [the victim] or [Patrie] was participating in the offense of Burglary . . . .

Patrie argues the State presented insufficient evidence that he shot the

victim. When reviewing a conviction for sufficiency of the evidence, “[w]e view the

evidence ‘in the light most favorable to the State, including all reasonable

inferences that may be fairly drawn from the evidence.’” State v. Ortiz, 905 N.W.2d

174, 180 (Iowa 2017) (citation omitted). We will uphold a conviction “if substantial

evidence supports it.” State v. Wickes, 910 N.W.2d 554, 563 (Iowa 2018) (citation

omitted). “Evidence is substantial if, ‘when viewed in the light most favorable to the

State, it can convince a rational [factfinder] that the defendant is guilty beyond a

reasonable doubt.’” Id. (citation omitted). Evidence is not insubstantial purely

because it may support a different conclusion; we simply ask whether evidence

supports the finding actually rendered. See State v. Jones, 967 N.W.2d 336, 339

(Iowa 2021).

Patrie focuses his argument on what he characterizes as the documented

unreliability of “jailhouse snitch testimony.” But because jailhouse testimony is 6

“highly relevant and . . . the matter of credibility [is] for the jury,” our courts allow

for its admission at trial, especially since “there is currently no toolbox of consensus

scientific principles that apply to the testimony of jailhouse informants.” State v.

Liggins, 978 N.W.2d 406, 427 (Iowa 2022). Patrie cites to no controlling authority

for his proposition that “[n]o conviction carrying a mandatory sentence of life

without parole should be primarily based on such unreliable testimony.” The

reliability of jailhouse testimony is for the factfinder to determine. See id.

The jailhouse informants in this case testified that Patrie had admitted to

key facts just as the State alleged they occurred, including that Patrie entered the

victim’s home through the garage with a stolen garage opener obtained while doing

some work for the victim, that Patrie believed there was a safe full of cash in the

home, and that Patrie shot the victim with a .410 shotgun and “covered the [victim]

with books and bookcase” because he felt like the dead victim was staring at him.

Even without the jailhouse informants’ testimony, the evidence against Patrie was

sufficient to convict him of first-degree murder.

Patrie argues that his uncle planned the robbery, knew where the victim

lived, and recruited Patrie to rob the victim. Even if true, none of those facts

contradict a factfinder’s conclusion that Patrie was guilty as charged. And Patrie

does not attempt to counter any of the other strong evidence against him besides

asserting that his uncle’s testimony was self-serving—a point Patrie had the

opportunity to emphasize to the jury during cross-examination.

Patrie’s uncle testified to the interest Patrie showed in the victim’s home and

that Patrie had been casing the home. Patrie’s uncle found out “at some point”

before the murder that the victim had $30,000 stolen from an open safe in his 7

home. In conversation a few weeks before the murder, Patrie’s uncle informed

Patrie that the victim had a large amount of cash stolen from a safe and, at one

point, he pointed out the house to Patrie while they were driving through town.

Patrie proceeded to ask questions about the home such as whether the home had

dogs. Sometime after that conversation, Patrie told his uncle that “he ran out of

gas or had a flat” outside of the victim’s home and had used the victim’s telephone

at the victim’s home. Patrie also asked his uncle if he would accompany Patrie to

go rob the victim, claiming the victim would be an “easy mark.”

A DCI agent testified to the large amount of debt Patrie owed—over

$30,000—in addition to a home mortgage and relatively low income of $1200 per

month. Patrie’s wife testified that, on the night of the murder, she woke up around

2:00 a.m. and Patrie was not in bed or any other part of the house and his car was

not in the driveway, causing her to wonder where he went because this behavior

was not normal. He did not appear home again during the “hour or two” it took her

to get back to sleep. Patrie was also not there when his wife woke up in the

morning, which “upset [her] because normally he is” home in the morning.

Shortly after 7:00 a.m., Patrie arrived home and backed up the vehicle to

his garage and started unloading items from the vehicle, including several firearms.

Firearms were missing from the victim’s home following the murder. Patrie’s wife

also testified that Patrie owned a sawed-off shotgun and that she had seen it in his

shed prior to the murder. Patrie’s wife was with Patrie when the victim’s death was

announced on the news, which caused Patrie’s face to turn “white as a ghost,” and

she observed “a shocked look on his face.” 8

Patrie discussed the crime with his uncle, calling the victim an “easy mark,”

and had cased the victim’s home. Patrie was missing from his home the night of

the murder, which was described by his wife as unusual. Patrie returned the next

morning and unloaded what appeared to be the stolen items from his vehicle. He

owned a sawed-off .410 shotgun, which was the weapon used to murder the victim

in his bed. He was in possession of many of the exact items that were missing

from the victim’s home, including television with matching serial number and

firearms hidden in the insulation of his attic. Patrie changed his story years later

and provided a retelling that included verifiably false information. He falsely

accused an individual who turned out to have an alibi. Multiple jailhouse

informants provided consistent stories detailing Patrie’s admissions relating to the

murder. In short, the evidence against Patrie, as the district court described, is

overwhelming. The State presented sufficient evidence for a reasonable factfinder

to conclude beyond a reasonable doubt that Patrie committed first-degree murder.

We affirm.