Iowa Supreme Court draws a line in two juvenile sentencing cases

By: Rox Laird on May 26th, 2017

When the Iowa Supreme Court began applying the U.S. Supreme Court’s recent juvenile sentencing decisions to Iowa cases, criminal offenders convicted as juveniles saw an opportunity to raise increasingly novel arguments.

Although the Court has agreed with some of those arguments, two decisions handed down Thursday suggest a majority of the Iowa justices are wary of going too far.

In both cases – State v. Sayvon Propps and State v. Bradley Graham – the Court held that sentencing judges and statutes are not necessarily required to show special deference for juveniles compared to adults.

The U.S. Supreme Court over the past decade has set a higher bar for juvenile sentences based on expert evidence that juvenile offenders are fundamentally different from adults. Their characters are not fully formed and they are thus less culpable than adult offenders.

Beginning in 2005 the nation’s high court handed down a series of rulings – beginning with the death penalty and followed by sentences of life without parole in homicide and non-homicide cases – declaring that certain sentences are cruel and unusual punishment for offenders under age 18.

Since then, the Iowa Supreme Court has followed suit with a half-dozen rulings of its own, including a decision in 2014 (State v. Lyle) that, in the case of juveniles, one-size-fits-all mandatory minimum prison sentences prescribed by the Legislature violate the Iowa Constitution’s equivalent of the Eighth Amendment.

Propps urged the Iowa Court to go the next step to declare that his mandatory prison sentence of four consecutive 10-year terms is cruel and unusual punishment under the Iowa Constitution. The Court, in a 5-2 decision, disagreed.

Propps pleaded guilty to a forcible felony, thus under Iowa law the district court had no choice but to sentence him to a term of imprisonment. Even though it is not a mandatory minimum sentence, he argued that statute is unconstitutional because it mandates a prison sentence for juveniles without considering the mitigating factors of the juvenile offender.

“Propps seeks to expand Lyle to cases such as his, even though he has no mandatory minimum period of incarceration and he is immediately eligible for parole,” Justice Bruce Zager wrote for the majority. “We decline to do so.”

Because his sentence was indeterminate, “Propps was immediately eligible for parole and able to demonstrate by his own actions his maturation and rehabilitation,” Zager wrote. “When a one-size fits-all mandatory minimum is imposed, an arbitrary amount of time spent in prison dictates when a juvenile will be released. In contrast, when an indeterminate sentence is given that contains no mandatory minimum sentence and allows a juvenile to be immediately eligible for parole, the juvenile defendant’s behavior in prison dictates when parole will be available — with the potential for immediate parole if rehabilitation, maturity, and reform have been demonstrated.”

Zager’s opinion was joined by Justices Thomas Waterman and Edward Mansfield. Chief Justice Mark Cady wrote a separate concurring opinion joined by Justice David Wiggins.

Writing in dissent, Justice Brent Appel said a mandatory prison sentence, however brief, violates the Lyle standard. “A prison term even for a relatively short period of time is crossing of a major Rubicon for the juvenile offender,” Appel wrote. “A trip to the big house, no matter how brief, is not a de minimis event.”

The Rubicon was not crossed in State v. Graham, the other juvenile sentencing case handed down Thursday – even for Appel, who wrote for a unanimous Court rejecting Graham’s appeal.

Graham pleaded guilty to sexual abuse when he was 17 and was sentenced to lifetime supervision by the Iowa Department of Corrections and required to register for life on the sex offender registry. Graham argued the lifetime parole and sex offender registration requirements were “inhumane” because he was a juvenile at the time of the offense.

The Court disagreed, in part because it in the past has held that lifetime sex offender registration as applied to adults was not punitive, and in part because Graham “simply does not present the kind of grossly disproportionate punishment based on his current parole status to support a cruel and unusual punishment claim with respect to his parole.”

Chief Justice Cady’s concurrence in Propps expressed how he, and perhaps a majority of the Court, decides how to draw the line in these juvenile sentencing cases.

Cady explained that the Court has applied evolving science about the juvenile brain development to the constitutional standard of cruel and unusual punishment and juveniles’ ability to be rehabilitated as they mature.

“The constitutional standard relies on time for this rehabilitation to occur,” Cady wrote. “It requires only an opportunity for these changes to be considered as directed by the advancements of science. Our constitutional standards need to grow along with our greater understanding, but no further.

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On Brief is devoted to appellate litigation, with a focus on the Iowa Supreme Court, the Iowa Court of Appeals, and the United States Court of Appeals for the Eighth Circuit.
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