Juvenile Offenders; Life Sentence without Parole

State v. Sweet, 879 N.W.2d 811 (Iowa 2016)

Iowa Supreme Court reverses and remands sentencing of a juvenile offender to life without parole in a doublemurder case, on the grounds that such a sentence violates the Iowa Constitution. (Vigorous dissent notes that the Court’s “categorical bar” of life without parole for juveniles goes beyond the U.S. Supreme Court’s decision in Miller v. Alabama.)

Background: Isaiah Sweet was 17 years old when he shot and killed his grandparents, who had raised him since the age of 4. He pled not guilty to two counts of first-degree murder, but after the State concluded its case, he pled guilty as part of a plea agreement with the State. The court entered an order for a presentence investigation report, per recent Iowa precedent concerning the sentencing of juveniles convicted of murder. After review of the report and expert testimony from a clinical psychologist, which detailed hardships in his life and the inherent difficulties of assessing risk in adolescents, Sweet was sentenced to life without the possibility of parole. Sweet appealed the sentence.

Holding: On appeal, The Iowa Supreme Court ruled that a sentence of life without the possibility of parole (LWOP) for a juvenile offender violates article I, section 17 of the Iowa Constitution. The Court noted that Sweet did not expressly cite the federal Eighth Amendment, so it proceeded with its analysis under the Iowa Constitution. The Court reviewed the history of federal Eighth Amendment case law up through the recent cases concerning juveniles (e.g., Miller v. Alabama), then reviewed Iowa case law. It noted that Iowa has extended the reasoning of recent federal cases to provide even greater protection to juveniles (e.g., requiring individualized hearings in cases involving long prison sentences short of life in prison without the possibility of parole). The Court ultimately held that a categorical bar on life without parole sentences was required under the Iowa Constitution.

Notable Points:

Categorical bar to LWOP replaces case-by-case analysis: The Iowa Supreme Court first assessed whether a consensus existed in favor of a categorical approach. The Court noted that nine states have abolished LWOP sentences for juveniles, and that another 13 have functionally barred the practice. It also noted, however, that several state supreme courts have concluded that a categorical bar is not necessary. Concluding that a consensus was not present, the Court then exercised its “independent judgment to determine whether to follow a categorical approach,” ultimately concluding “that sentencing courts should not be required to make speculative up-front decisions on juvenile offenders’ prospects for rehabilitation because they lack adequate predictive information supporting such a decision.” Instead, “[t]he parole board will be better able to discern whether the offender is irreparably corrupt after time has passed, after opportunities for maturation and rehabilitation have been provided, and after a record of success or failure in the rehabilitative process is available.”

Found in DMHL Volume 35, Issue 2