State v. Seats

Defendant was seventeen years old when he committed first-degree murder. Defendant was sentenced to life without parole, as required by Iowa law. Defendant later filed a motion to correct an illegal sentence. Before the trial court heard the motion and shortly after Miller v. Alabama was decided, Iowa’s Governor commuted the sentences of all juveniles previously convicted of first-degree murder to a life sentence with the possibility of parole after sixty years. The trial court then granted Defendant’s motion to the extent his sentence was imposed without “individualized consideration of the circumstances.” The court upheld Defendant’s sentence of life with parole eligibility after sixty years as commuted by the Governor. The Supreme Court vacated the sentence, holding (1) a court must use certain factors when it sentences a juvenile offender for first-degree murder; and (2) because the district court did not have the benefit of this decision when it sentenced Defendant, this case must be remanded for resentencing. View "State v. Seats" on Justia Law