Last year, the U.S. Supreme Court ruled in Miller v. Alabama that mandatory sentences of life without the possibility of parole are unconstitutional for juvenile offenders. That was a challenge for Iowa, which had until then required that anyone convicted of first-degree murder — juvenile or adult — be given that sentence. In response to the ruling, Governor Terry Branstad immediately used his commutation power to change the sentences of 38 such juvenile offenders to allow parole — but only after they had served 60 years behind bars.
Today, the Iowa Supreme Court made clear that solution was not satisfactory. In three separate rulings, the high court stated unequivocally that the reasoning of Miller v. Alabama simply could not be squared with the governor’s actions.
Miller v. Alabama held that there is clear scientific evidence that juveniles are developmentally less able to control their impulses, consider consequences and make lawful decisions, so they are less culpable for their crimes. Because they are still developing — and at individual rates — juvenile sentencing must be “tailored in a meaningful way” to the individual circumstances.
“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,” the court wrote. No mandatory-minimum sentences or cookie-cutter outcomes are acceptable.
As a result of these three landmark cases, three people convicted of murder of juveniles got reduced sentences, even though only one of them was sentenced to live without parole.
- One 44-year-old man convicted at age 17 of first-degree murder, but only as an accessory, had his mandatory sentence of life without parole reduced to life with the possibility of parole after 25 years.
- A 20-year-old man will see a reduction to his 2010 mandatory-minimum sentence of 52 years for a robbery and murder he was convicted of at age 16.
- A 19-year-old woman convicted of robbery and burglary in 2010 was sentenced to a mandatory-minimum of 35 years in prison, and will also see a reduction.
As of now, there are 425 juveniles imprisoned in Iowa, according to one justice’s dissent, and all of those serving mandatory-minimum sentences can now seek resentencing to take into consideration factors such as personal history, psychiatric condition, economic background, and substance abuse. Information about those factors is already gathered customarily, but mandatory-minimums ban judges from considering them.
Finally, opponents of the ruling may find it difficult to pass a law to overturn it. The Iowa Supreme Court based its reasoning on both the federal and Iowa constitutions.
Source: Des Moines Register, “UPDATE: Hundreds of juveniles could appeal felony sentences under Iowa court rulings,” Grant Rodgers, Aug. 16, 2013