Joseph Wayne Miller, Applicant-Appellant v. State of Iowa, 16-0859

Between Dec. 2008 and Feb. 2009, Joseph Miller (age 28) engaged in a sexual relationship with a girl who was 13–14 during that period.
State charged Miller with third-degree sexual abuse; discovery showed the relationship began when the victim was 13 and Miller transported her across state lines, exposing him to an enhanced second-degree charge.
Miller pleaded guilty on June 12, 2009, to avoid the enhanced charge; sentence not to exceed 10 years, lifetime parole special sentence under Iowa Code § 903B.1, and sex-offender registration.
Trial counsel did not recall discussing the specific future conditions of lifetime parole at the plea; Miller contended he was unaware of many parole conditions and would have gone to trial if he had known.
Miller was released on parole in Aug. 2014 with conditions forbidding contact with minors (including his children), social-media use, and pornography; parole was revoked in Dec. 2014 for parole violations and Miller sought postconviction relief, which the district court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of counsel for failing to advise about lifetime-parole consequences	Miller: counsel failed to inform him of parole conditions; he would have gone to trial if informed	State: counsel cannot predict future parole conditions; no duty to forecast rules not yet set	Court: No ineffective assistance — counsel not required to "crystal gaze" future parole conditions
Cruel and unusual punishment—lifetime parole is grossly disproportionate	Miller: lifetime parole is excessive compared to his offense (characterized as "Romeo and Juliet")	State: crime involved a significantly older abuser and repeated acts; legislature intended enhanced protection for children	Court: No Eighth Amendment violation — threshold of gross disproportionality not met; sentence affirmed

Ledezma v. State, 626 N.W.2d 134 (Iowa 2001) (standard and burden for ineffective-assistance claims)
Snethen v. State, 308 N.W.2d 11 (Iowa 1981) (counsel not required to predict future changes in law)
State v. Oliver, 812 N.W.2d 636 (Iowa 2012) (three-step disproportionality analysis for Eighth Amendment challenges)
State v. Clay, 824 N.W.2d 488 (Iowa 2012) (definition of counsel's essential duties and competency presumption)
Taylor v. State, 352 N.W.2d 683 (Iowa 1984) (limits of attacking counsel for strategic choices)
Jones v. State, 479 N.W.2d 265 (Iowa 1991) (preponderance standard for proving ineffective assistance)
State v. Sallis, 786 N.W.2d 508 (Iowa Ct. App. 2009) (noting sexual crimes as particularly heinous)