State v. Harrison

Donald Harrison appeals his conviction of second-degree theft in violation of Iowa Code section 714.1(4) (1993). He argues that theft by exercising control over stolen property is not a continuing offense for purposes of the statute of limitations set forth in Iowa Code section 802.3; therefore, the district court erred in denying his motion to dismiss. We reverse.

On May 21, 1993, police executed a search warrant for Harrison’s property and found stolen construction equipment. On December 29, 1993, Harrison was charged by trial information with the offense of theft by exercising control over…