Iowa Supreme Court 2016-17 Preview: Court asked to go further on juvenile sentences

by Rox Laird | December 2, 2016

The Iowa Supreme Court will hear arguments this month in three cases that could add to a growing body of Iowa law regarding sentencing of juvenile criminal offenders.

In one case, the Court is urged to rule that the appellant’s mandatory minimum sentence was wrongly upheld by a trial court on review. In a second, the appellant argues that mandatory minimum sentences should be held categorically unconstitutional for juveniles. The third appellant asks the court to rule it unconstitutional to subject a juvenile to lifetime parole and lifetime listing on the sex-offender registry.

The three cases scheduled to be argued Dec. 14 and 15 follow a series of rulings from the U.S. Supreme Court dating back a decade or more based on expert evidence that juvenile offenders are fundamentally different from adults. Their characters are not fully formed, studies show, and they are thus less culpable than adult offenders.

Beginning in 2005 the nation’s high court handed down a series of rulings – beginning with the death penalty and followed by sentences of life without parole in homicide and non-homicide cases – declaring that certain sentences are cruel and unusual punishment for offenders under age 18.

Since then, the Iowa Supreme Court has followed suit with a half-dozen rulings of its own, including a decision in 2014 (State v. Lyle) that, in the case of juveniles, one-size-fits-all mandatory minimum prison sentences prescribed by the Legislature violate the Iowa Constitution’s equivalent of the Eighth Amendment.

The Court in Lyle said a juvenile could be sentenced to a minimum prison term before being eligible for parole, but there must be a finding by a trial court that weighs a number of mitigating factors, including the offender’s age, family and home life, the nature of the crime and his or her potential for reform.

All three appeals set for December argument ask the court to clarify or expand on the Lyle decision.

In State v. Majors, appellant Jarrod Majors argues that the trial court misapplied Lyle’s mitigating factors in upholding his minimum sentence of 24½ years. Majors wants his case sent back for a rehearing by the District Court.

In State v. Roby, appellant Christopher Roby argues that the mitigating factors set out in Lyle have been so inconsistently applied in various cases that the Court should simply declare that mandatory minimum sentences of all juvenile offenders are categorically unconstitutional.

In the third case, State v. Graham, appellant Bradley Graham argues that his sentence, which included lifetime parole supervision and lifetime listing on the sex-offender registry following his release from prison, is unconstitutional because he was a juvenile at the time of his conviction.

In briefs filed with the Court representing the state, the Iowa Attorney General, rejects all three arguments.

In Majors, the state says the trial court properly considered the Lyle mitigating factors. In Graham, the state points out that Graham’s lifetime parole can be shortened by the Iowa Board of Parole and sex-offender registry conditions can be changed after five years, thus resolving any constitutional questions.

As for declaring all mandatory minimum sentences for juveniles unconstitutional, the Attorney General said the Court’s 2014 decision in Lyle was the “logical end point.” By “replacing mandatory sentences with individualized consideration of ‘youth and its attendant circumstances,’ Lyle resolved the constitutional infirmity and ended the need for further judicial control of the Legislature’s power to set the boundaries of criminal sentencing.”

[Note: Go to On Brief’s Cases in the Pipeline page to read the appellant’s and appellee’s briefs in these cases.]


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On Brief: Iowa’s Appellate Blog is devoted to appellate litigation with a focus on the Iowa Supreme Court, the Iowa Court of Appeals, and the U.S. Court of Appeals for the Eighth Circuit.


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