Articles Posted in Juvenile Law

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A hearing conducted by the district court to determine if a juvenile offender should be sentenced to a minimum term of incarceration without eligibility for parole did not, in this case, comply with constitutional safeguards. The district court concluded that the juvenile in this case should serve the statutory mandatory minimum term of incarceration before becoming eligible for parole. The court of appeals affirmed. The Supreme Court reversed, holding that the district court abused its discretion in its application of the sentencing factors because critical conclusions drawn by the court at the sentencing hearing were not grounded in science but rather based on generalized attitudes of criminal behavior that may or may not be correct as applied to juveniles. The court remanded the case for resentencing in light of State v. Roby, 897 N.W.2d, 127 (Iowa 2017). View "State v. White" on Justia Law

Posted in: Juvenile Law

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Iowa Const. art. I, section 17 does not categorically prohibit a district court form sentencing a juvenile offender to a minimum term of incarceration without the possibility of parole, provided that the court only imposes the sentence after a complete and careful consideration of the relevant mitigating factors of youth. Defendant, who was a juvenile at the time of his offense, was resentenced to a minimum term of incarceration of seventeen and one-half years for sexual abuse in the second degree. Defendant appealed, arguing that any minimum term of incarceration without the possibility of parole is unconstitutional. The court of appeals affirmed the sentence. The Supreme Court remanded for resentencing, holding that, while the Iowa Constitution does not require abandonment of the practice at issue, the district court abused its discretion in this case by imposing a sentence of incarceration without parole eligibility. View "State v. Roby" on Justia Law

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Defendant, a juvenile, pleaded guilty to four counts of willful injury causing serious injury. Pursuant to the plea agreement, the district court sentenced Defendant to indeterminate sentences not to exceed ten years on each of the four counts to run consecutively for a maximum sentence of forty years. No mandatory minimum sentence was imposed, but because Defendant’s crime was a forcible felony, the sentencing judge was unable to consider a deferred judgment or probation as a sentencing option. Defendant filed a motion to correct an illegal sentence, which the district court denied. The Supreme Court affirmed the judgment of the district court, holding (1) the forcible felony sentencing statute, Iowa Code 907.3, is not unconstitutional as applied to juvenile offenders; and (2) in considering a motion to correct an illegal sentence, the district court is not required to conduct an individualized sentencing hearing as to all juveniles regardless of whether the sentence has a mandatory term of years. View "State v. Propps" on Justia Law

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Defendant pleaded guilty to attempted murder. Defendant was sixteen years old at the time of the offense. Defendant was sentenced to twenty-five years in prison, including a mandatory minimum term of incarceration. Defendant was also ordered to pay $150,000 in mandatory restitution to the victim’s estate. Defendant was later resentenced and received immediate parole eligibility because the mandatory minimum period of incarceration had been deemed unconstitutional. The restitution was left in place. Defendant appealed, challenging the $150,000 in restitution to the victim’s estate. The Supreme Court affirmed, holding (1) the $150,000 mandatory restitution for juvenile homicide offenders is not facially unconstitutional; and (2) the $150,000 mandatory restitution was not unconstitutional as applied to Defendant. View "State v. Breeden" on Justia Law

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Defendant pleaded guilty to second-degree murder. Defendant was fifteen years old at the time of the offense. The district court sentenced Defendant to an indeterminate term of incarceration and ordered Defendant to pay $150,000 in mandatory restitution to the victim’s estate. Defendant appealed, challenging the $150,000 restitution award. The Supreme Court affirmed, holding (1) Iowa Code 901.5(14) does not authorize the district court to modify a restitution award otherwise required by Iowa Code 910.3B(1), and restitution under chapter 910 is mandatory; and (2) section 910.3B is not unconstitutional either as applied to all juvenile homicide offenders or as applied to Defendant. View "State v. Richardson" on Justia Law

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The Iowa District Court for Story County issued an order appointing the local public defender of Nevada, Iowa to represent a juvenile, who had been detained. The public defender filed a motion to withdraw, citing conflicts of interest between the juvenile and other clients. After a detention hearing, the court ordered the juvenile’s transfer from detention to shelter care and then withdrew the local defender’s appointment and appointed new conflict-free counsel for the juvenile. The court subsequently taxed to the state public defender the court and travel costs related to the hearing for withdrawing from the representation of the juvenile prior to the hearing without first taking steps to secure alternative representation for the juvenile. The state public defender filed a petition for writ of certiorari in the Supreme Court, claiming that the district court acted illegally when it taxed the court and travel costs against the state public defender. The Supreme Court sustained the writ, holding that the district court exceeded its authority and made an error of law in determining that the state public defender or the local public defender violated either statutory or ethical duties under the circumstances of this case. View "State Public Defender v. Iowa District Court" on Justia Law

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In 2012, seventeen-year-old appellant Isaiah Sweet shot and killed Richard and Janet Sweet. Richard and Janet had cared for Sweet since he was four years old, as his biological mother was unable to do. Richard was Sweet’s biological grandfather. Richard and Janet had been married for thirty years. Sweet was arrested three days after the murder. After being given Miranda warnings, Sweet described events leading to the murders, the details of the murders themselves, and his activities in the days after the murders. Sweet was charged and convicted on first-degree murder charges. While his maturity was debatable, the district court stressed that the crimes were premeditated. The district court felt that Sweet's proffered expert's characterization of Sweet’s possibility of rehabilitation as "mixed" was overly optimistic. Further, the district court found Sweet’s case was the rare case in which a sentence of life without the possibility of parole was warranted, as the murders were horrific and showed utter lack of humanity. The district court concluded that Sweet was currently, and will continue to be, a threat to society and that the interests of justice and community safety outweighed mitigating factors. Sweet was sentenced to life without the possibility of parole. The Supreme Court reversed and remanded for resentencing, finding that a sentence of life without the possibility of parole for a juvenile offender violated article I, section 17 of the Iowa Constitution. View "Iowa v. Sweet" on Justia Law

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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

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Fifteen-year-old D.S. was accused of harassing a peer during an after-school confrontation. The State filed a petition alleging that D.S. had committed a delinquent act, specifically harassment in the third degree. After an adjudicatory hearing, the juvenile court concluded that the State had proven beyond a reasonable doubt that D.S. committed harassment in the third degree by means of intimidation. The court then adjudicated D.S. to have committed a delinquent act. The Supreme Court reversed, holding that there was insufficient evidence in the record to support the finding that D.S. committed harassment, and therefore, the juvenile court erred when it adjudicated D.S. delinquent under the harassment statute. Remanded for an order dismissing the petition. View "In re Interest of D.S." on Justia Law

Posted in: Juvenile Law

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When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law