James Elvin Dorsey v. State of Iowa, 19-1917

In 1984 James Dorsey (18 years, 5 days) entered Juanita Weaver’s home, shot and killed her; convicted of first-degree murder and sentenced to mandatory life imprisonment without parole (LWOP).
Dorsey filed multiple postconviction challenges over decades; his 2014 motion to correct an illegal sentence argued LWOP for youth violated federal and state Eighth Amendment principles; district court denied relief.
Dorsey’s fifth postconviction application sought to extend Iowa decisions (notably Lyle and Sweet) that limited harsh mandatory sentences for juveniles to young adults, requesting either a categorical rule or an individualized (Miller-type) sentencing hearing.
The district court dismissed on statute-of-limitations and res judicata grounds and rejected the merits; the Iowa Supreme Court treated the filing as a motion to correct an illegal sentence, granted certiorari, and reviewed the claims.
The Iowa Supreme Court affirmed: statute-of-limitations and res judicata did not bar review, but the court declined to extend juvenile categorical protections to young adults and rejected Dorsey’s gross-disproportionality challenge to his LWOP sentence.
Justice Appel dissented, arguing for remand for an individualized hearing requiring the State to prove incorrigibility before imposing LWOP on a young adult.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Statute of limitations	Dorsey: claim not time-barred because it's a motion to correct illegal sentence	State: postconviction statute (Iowa Code §822.3) bars claim	Held: Motion was properly treated as motion to correct an illegal sentence and is not governed by the 3‑year postconviction limitation.
2) Res judicata / prior motion	Dorsey: new Iowa precedents (Lyle/Sweet) permit reconsideration despite prior 2014 motion	State: prior 2014 motion raised same claim; barred by res judicata	Held: Not barred—prior order addressed federal claim only and later state-law developments justify reconsideration.
3) Extension of juvenile rule / Miller hearing for young adults	Dorsey: Lyle/Sweet principles (youth mitigators) should extend to 18–24 year-olds; at least a Miller-type individualized hearing required	State: Iowa law draws a bright line at 18; Lyle/Sweet apply only to juveniles; legislature prescribes penalties	Held: Court refuses to extend Lyle/Sweet to young adults; adheres to bright-line at 18 and denies mandatory‑sentence/automatic‑Miller‑hearing relief.
4) Gross disproportionality of LWOP as‑applied	Dorsey: LWOP for an 18-year-old is grossly disproportionate given age and mitigating science	State: LWOP for first-degree murder is a proportionate, legislatively authorized maximum penalty	Held: No inference of gross disproportionality; sentence for willful, premeditated murder affirmed.

Miller v. Alabama, 567 U.S. 460 (2012) (juveniles require consideration of youth; mandatory LWOP unconstitutional for juveniles)
Graham v. Florida, 560 U.S. 48 (2010) (LWOP for nonhomicide juvenile offenders prohibited; meaningful opportunity for release required)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for offenders under 18)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (mandatory minimums for youthful offenders unconstitutional under Iowa Const.)
State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (categorical ban on LWOP for juvenile offenders under Iowa Const.)
State v. Null, 836 N.W.2d 41 (Iowa 2013) (Miller-type protections apply to lengthy juvenile sentences; individualized hearing required)
State v. Bruegger, 773 N.W.2d 862 (Iowa 2009) (three‑part gross‑disproportionality test and timing for as‑applied challenges)
Bonilla v. State, 791 N.W.2d 697 (Iowa 2010) (applications alleging illegal sentence should be treated as motions to correct illegal sentence)
Veal v. State, 779 N.W.2d 63 (Iowa 2010) (motions to correct illegal sentence are not subject to the 3‑year postconviction statute of limitations)
State v. Fuhrmann, 261 N.W.2d 475 (Iowa 1978) (upholding life sentence for first‑degree murder)