State of Iowa v. Alphonzo David Dillon Jr., 15-1186

Defendant Alphonzo David Dillon Jr. was convicted of lascivious acts with a child under Iowa Code § 709.8(2).
After his original sentence was vacated on appeal, he was resentenced on July 2, 2015.
The district court imposed ten years' imprisonment, a fine, and a mandatory lifetime special sentence of supervision under Iowa Code § 903B.1.
Dillon challenged the mandatory lifetime supervision as violating separation-of-powers principles by infringing the court’s sentencing discretion.
The State argued the legislature may define crimes and fix mandatory penalties; prior Iowa precedent upheld similar mandatory sentencing schemes.
The Court of Appeals reviewed the constitutional challenge de novo and affirmed the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Iowa Code § 903B.1’s mandatory lifetime special sentence violates separation of powers by infringing judicial sentencing discretion	Legislature may set crimes and mandatory penalties; mandatory supervision is within legislative power and consistent with precedent	Mandatory lifetime supervision unlawfully restricts judicial discretion in sentencing and infringes separation of powers	Affirmed. § 903B.1 is constitutional; mandatory lifetime supervision does not violate separation-of-powers principles

State v. Wade, 757 N.W.2d 618 (Iowa 2008) (upheld mandatory lifetime supervision statute)
State v. Phillips, 610 N.W.2d 840 (Iowa 2000) (statutorily mandated minimum sentences do not infringe executive power)
State v. Ronek, 176 N.W.2d 153 (Iowa 1970) (legislature’s power to define crimes and penalties)
State v. Holmes, 276 N.W.2d 823 (Iowa 1979) (statutory preclusion of probation does not infringe judicial discretion)
State v. Keene, 629 N.W.2d 360 (Iowa 2001) (constitutional challenges reviewed de novo)
State v. Beck, 854 N.W.2d 56 (Iowa Ct. App. 2014) (appellate courts must follow controlling supreme court precedent)