UPDATES & ANALYSIS

Iowa Supreme Court declines to extend juvenile sentencing protections to young adults in two cases

by Nathan Wegmann | June 14, 2022

James Dorsey broke into a home before shooting and killing an unarmed woman just five days after he turned eighteen in 1984. Dorsey was convicted of first-degree murder and he received the mandatory sentence for first-degree murder – life in prison without the possibility of parole. The case before the Iowa Supreme Court was Dorsey’s challenge of his sentence as cruel and unusual punishment in violation of Iowa Constitution Article I Section 17. This is not Dorsey’s first challenge of his sentencing or conviction: in 1986 his conviction was affirmed on direct appeal; in 1986 he had applications for post-conviction relief dismissed as meritless; in 1994, 1999 & 2008 he had applications for post-conviction relief dismissed each time because they were time-barred; and in 2014 he filed a motion to correct an illegal sentence. His challenge in 2014 was similar to the case before the Court as he alleged the sentence should be considered cruel and unusual punishment in violation of both the state and federal constitutions. His 2014 federal claim was denied by the Court while the state claim was not addressed.

Dorsey’s current challenge was filed as an application for post-conviction relief. Procedurally, the district court granted the State’s motion for summary disposition for three reasons: (1) Dorsey’s application for postconviction relief was time-barred; (2) Dorsey’s claims, to the extent they were not time-barred – were barred by res judicata from his motion in 2014; and (3) he was not entitled to any relief on the merits. The Iowa Supreme Court ruled that the three-year statute of limitations on applications for post-conviction relief did not apply because this request was more properly categorized as a motion to correct an illegal sentence, which is a motion that can be brought at any time. The Court also concluded that the claims were not barred by res judicata (meaning the claim has already been decided) because the state constitutional claim was not previously ruled upon in 2014, and there has been a change in the governing law since his last motion was denied.

Dorsey’s challenge to his sentence under the Iowa Constitution was denied in an opinion authored by Justice McDonald in which all justices except Justice Appel joined.  The challenge was based on two Iowa Supreme Court cases which were decided since his failed 2014 application: State v. Lyle and State v. Sweet.  “In Sweet and Lyle, [the] court held article I, section 17 [of the Iowa Constitution] circumscribes the legislature’s prerogative in imposing certain punishments on juvenile offenders.”  Lyle is a 2014 case in which the Court held that “all mandatory minimum sentences of imprisonment for youthful offenders are unconstitutional under the cruel and unusual punishment clause in article I section 17 of [the Iowa] constitution.” Sweet, a case from 2016, instituted “a categorical rule that juvenile offenders may not be sentenced to life without the possibility of parole under article I, section 17 of the Iowa Constitution.” The crux of Dorsey’s argument on appeal was that these cases should be extended to young adults.

The Sweet and Lyle sentencing limitations were based on medical science showing the human brain continues to develop until the person reaches twenty-five years of age and social science findings that juveniles and young adults “lack the ability to properly assess risks and engage in adult-style self-control.” Based on these justifications, Dorsey argued, the Court should require individualized sentencing hearings – in lieu of mandatory minimum sentences – to everyone under the age of twenty-five, or at a bare minimum, to a person in his position who committed his crime just five days after turning 18. Dorsey contends that the bright-line rule for sentencing protections only extending to those under eighteen years of age is arbitrary and conflicts with the scientific findings on which Sweet and Lyle were based.

The Court declined to extend the sentencing protections of Sweet and Lyle to young adults over the age of eighteen. The Court noted that Lyle explicitly stated that such a bright line rule is drawn by necessity and that the decision has no impact on the sentencing of adult offenders. The Court also said that 18 years old is not an arbitrarily drawn line, instead it is “based on the long-accepted legal categorical distinction drawn between juveniles and adults.”

The Court also denied Dorsey’s challenge to his sentence as unconstitutional cruel and unusual punishment based on the argument that his sentence was “grossly disproportionate” to the crime. The Court noted that first-degree murder is “considered the greatest universal wrong,” so “the proportionate response is to impose the greatest punishment allowed under our law, life imprisonment without the possibility of parole.”

Justice Appel filed a dissenting opinion in which he agreed with Dorsey’s arguments and found that the case should be remanded to the district court for an individualized sentencing hearing. Appel’s dissent focused on the harshness of the life without the possibility parole sentence, and he noted how our sentencing jurisprudence should continue to evolve with the advanced scientific and social-scientific understandings of the young adult mind. Appel wrote that a life without the possibility of parole flies in the face of one of the theories of criminal liability: rehabilitation. Appel noted that by incarcerating young people without the hope of ever being free, all incentive to become a better person is gone, and a life of hopelessness is all that remains.

Sandoval v. State, an opinion filed the same day as Dorsey, similarly addressed the constitutionality of sentencing a young adult to life in prison without the possibility of parole. Like Dorsey, Sandoval was convicted of first-degree murder as a young adult and sentenced to life in prison without the possibility of parole. Sandoval’s claim for post-conviction relief due to ineffective counsel was denied by the district court as time-barred by the three-year statute of limitations. Unlike Dorsey, Sandoval’s application for post-conviction relief was not an allegation that the sentence was illegal, so it was not classified as a motion to correct an illegal sentence and the Court dismissed the claim. However, for the first time on appeal Sandoval challenged his sentence as illegal, and as noted in Dorsey, such a claim can be brought at any time. Sandoval challenged the constitutionality of the “practice of imposing mandatory life sentences without the possibility of parole on nonjuvenile teenage offenders.”  Relying on the logic used to decide Dorsey, the majority, in an opinion also authored by Justice McDonald and joined by all justices except for Appel, found the sentence to be constitutional and dismissed Sandoval’s challenge. Appel dissented, stating “for the reasons expressed in Dorsey v. State, I would remand this matter to the district court for a hearing on the issue.”

Tags: Iowa Supreme Court 2021-2022