UPDATES & ANALYSIS

Iowa’s Supreme Court justices unanimous in a juvenile-sentencing decision

by Rox Laird | April 24, 2018

Iowa’s Supreme Court justices are often divided in juvenile sentencing cases, but they found common ground in a decision handed down April 20: The State can prosecute a juvenile as young as age 13.

Noah Riley Crooks argued in an appeal to the Supreme Court that the State cannot legally or constitutionally prosecute a 13-year-old accused murderer in adult court. In its decision handed down April 20, however, the Court said Iowa’s youthful offender statute “unambiguously” allows prosecution of offenders as young as 13, and such prosecutions do not violate the Iowa Constitution.

All seven justices agreed with that conclusion in the decision by Justice Thomas Waterman joined by Chief Justice Mark Cady and Justices Edward Mansfield and Bruce Zager. Justice Brent Appel filed a separate concurring opinion, joined by Justices Daryl Hecht and David Wiggins, dissenting on a separate issue of the trial court’s procedure for sentencing Crooks.

Under the youthful-offender process, a juvenile is tried as an adult and, if convicted, remains under the jurisdiction of the juvenile system until reaching the age of 18. At that point the District Court conducts a sentencing hearing. The sentence may range from immediate release to a prison term.

Crooks was found guilty by a Mitchell County jury of second-degree murder in the shooting death of his mother. He was 13 at the time of the crime, and he was waived by a juvenile court judge into adult court to be tried as a youthful offender. After he turned 18, following his commitment to the State Training School, Crooks was sentenced to up to 50 years in prison with immediate eligibility for parole.

The Supreme Court rejected Crooks’ argument that the Iowa Legislature did not intend a 13-year-old to be prosecuted in adult court under the youthful-offender statute. In fact, Justice Waterman wrote, the Legislature used different age limits throughout the juvenile-justice statutes, it “knows how to set a lower age limit” and it “chose to include thirteen-year-olds within the youthful-offender waiver provision.”

Crooks also argued that prosecuting youthful offenders as young as 13 is unconstitutional in two ways: First, the process of waiving a juvenile into adult court as a youthful offender is by itself cruel and unusual punishment; and, sentencing a juvenile in adult court for a crime committed at age 13 is categorically unconstitutional.

The Court rejected both arguments.

Waterman wrote that Iowa’s waiver provision for youthful offenders does not constitute punishment within the meaning of the Iowa Constitution, let alone “cruel and unusual” punishment. And Iowa’s youthful-offender process exceeds the constitutional requirements imposed by the U.S. Supreme Court and the Iowa Supreme Court with regard to sentencing juveniles.

While concurring in part with the majority opinion, Justice Appel dissented in part to say the District Court at the sentencing stage should have made specific findings considering “the mitigating factors of youth when sentencing children in adult court.”

Tags: Criminal Law, Iowa Constitution, Iowa Supreme Court 2017-18, Iowa Supreme Court Opinions