State v. Lyle
Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law