UPDATES & ANALYSIS

Iowa Supreme Court upholds minimum prison term for juvenile convicted of murder

by Rox Laird | October 18, 2024

The Iowa Supreme Court upheld a 35-year minimum prison sentence for a Fairfield juvenile who pleaded guilty to first degree murder for the death of his high school Spanish teacher. In its unanimous decision, the Court rejected the defendant’s argument that, under the Iowa Constitution, the State must present expert testimony showing a minimum sentence is necessary for a juvenile offender.

Willard Miller was charged with the murder of Fairfield High School Spanish teacher Nohema Graber, whose class Miller feared he was failing. His classmate, Jeremy Goodale, pleaded guilty to first-degree murder for his part in the death of Graber and was sentenced to life in prison with the possibility of parole after serving 25 years.

Miller pleaded guilty to first-degree murder and agreed to challenge only his sentence, not his guilty plea or conviction, in any appeal. Prior to sentencing, the State asked for a 30-year minimum sentence. Miller sought a sentence with no mandatory minimum.

Miller argues that the Iowa Constitution requires that before a juvenile offender is sentenced to a minimum term of incarceration before being eligible for parole, the State must present expert testimony showing the juvenile’s psychological traits prove a minimum sentence is necessary.

In disagreeing with Miller’s invitation to “alter the constitutional landscape of our juvenile sentencing jurisprudence,” the Court reviewed state and federal juvenile sentencing precedents dating back to the U.S. Supreme Court’s 2005 decision in Roper v. Simmons, which held that capital punishment for juvenile offenders is cruel and unusual punishment based on differences in maturity between juvenile and adult offenders.

Roper and subsequent U.S. Supreme Court decisions related to sentencing of juvenile offenders led to changes in juvenile sentencing by the Iowa Supreme Court, including State v. Lyle in 2014, which held that Article I, section 17 of the Iowa Constitution “prohibits the one-size-fits-all mandatory sentencing for juveniles.”

While the Court in Lyle stopped short of prohibiting mandatory minimum sentences for juvenile offenders, it established five factors that sentencing courts must consider before imposing minimum sentences, including the age of the offender, the juvenile’s family and home environment, and the possibility of rehabilitation and capacity for change.

Four years later, the Court in State v. Zarate reaffirmed that the Iowa Constitution does not “categorically” prohibit sentencing juveniles convicted of first-degree murder to life in prison with the possibility of parole only after serving a minimum term of confinement.

“Our decisions in Zarate and the subsequent cases following it remain good law,” Chief Justice Susan Christensen wrote for the Court in the Oct. 11 decision, “and the Iowa Constitution does not prohibit sentencing juvenile offenders to a minimum term of incarceration before parole eligibility as long as the offender receives an individualized sentencing” based on sentencing factors prescribed by the Court.

Miller argued that in addition to considering those sentencing factors, the district court must consider expert testimony regarding the defendant’s youthful characteristics and that the offender falls outside the “normal and generally accepted psychological makeup” before sentencing a juvenile offender to a minimum sentence.

The Iowa Supreme Court disagreed, saying there is no national consensus among courts, including the U.S. Supreme Court, regarding Miller’s argument, nor did the Iowa Legislature establish an expert testimony requirement for juvenile sentences in legislation that provides 22 factors that district courts must consider in determining a juvenile offender’s sentence.

Moreover, the Chief Justice wrote, the Iowa Constitution does not require it, noting that juveniles over the age of 14 were tried and sentenced as adults when the Iowa Constitution was adopted in 1857.

Finally, the Court disagreed with Miller’s argument that the district court abused its discretion in sentencing him to a minimum term, including by misapplying the sentencing factors. “A review of the district court’s statements in full shows that the district court properly applied the law to impose a sentence authorized by statute and supported by the evidence,” the Court concluded.

Tags: Iowa Supreme Court 2024-25