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Monday, August 19, 2013

Iowa Supreme Court: Sentences of Mandatory Life Without Parole (or Practical Equivalent) for Juveniles is Unconstitutional

In three opinions released last Friday, the Iowa Supreme Court ruled that Iowa's constitution prohibits courts from imposing a sentence of life in prison without the possibility of parole for juvenile offenders.  The Court notably applied this rule to cases involving sentences that are the "practical equivalent" of life in prison without parole -- meaning that defendants sentenced to lengthy prison terms may still challenge these sentences if they result in the defendants effectively spending the rest their lives in prison.

The cases are:




I thought that this excerpt from Ragland did a good job summarizing the Court's holdings and reasoning:

[T]he rationale of Miller, as well as Graham, reveals that the unconstitutional imposition of a mandatory life-without-parole sentence is not fixed by substituting it with a sentence with parole that is the practical equivalent of a life sentence without parole. Oftentimes, it is  important that the spirit of the law not be lost in the application of the  law. This is one such time. The spirit of the constitutional mandates of  Miller and Graham instruct that much more is at stake in the sentencing  of juveniles than merely making sure that parole is possible. In light of  our increased understanding of the decision making of youths, the sentencing process must be tailored to account in a meaningful way for  the attributes of juveniles that are distinct from adult conduct. At the  core of all of this also lies the profound sense of what a person loses by  beginning to serve a lifetime of incarceration as a youth.  
In the end, a government system that resolves disputes could  hardly call itself a system of justice with a rule that demands  individualized sentencing considerations common to all youths apply only to those youths facing a sentence of life without parole and not to those youths facing a sentence of life with no parole until age seventy-eight. Accordingly, we hold Miller applies to sentences that are the  functional equivalent of life without parole. The commuted sentence in  this case is the functional equivalent of a life sentence without parole.
The Des Moines Register reports on the case here.

(H/T: Howard Bashman at How Appealing)

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