State of Iowa v. Bradley Steven Graham, 2017 Iowa Sup. LEXIS 58

Background

In 2010 Graham (age 17 at offense) pled guilty to one count of third-degree sexual abuse involving a 13-year-old; he received an indeterminate prison term (up to 10 years) plus a mandatory special sentence of lifetime parole under Iowa Code §903B.1 and lifetime sex-offender registration under chapter 692A.
Graham filed a pro se motion to correct an illegal sentence arguing lifetime parole and lifetime registration are cruel and unusual because he was a juvenile. The district court ordered a resentencing hearing but ultimately denied relief.
At resentencing Graham’s counsel sought suspension of lifetime parole except for 10 years and sought to suspend the 2000-foot residency restriction; counsel did not contest a 10-year special sentence and presented limited evidence (parole-officer email, DOC reports).
The State argued Graham may seek early discharge or modification administratively (Iowa Code §906.15 and §692A.128) and that the statutes provide parole eligibility and administrative mechanisms.
The Iowa Court of Appeals treated Graham’s appeal via certiorari and affirmed; the Iowa Supreme Court granted further review and affirmed the lower courts, rejecting Graham’s categorical and as-applied Eighth Amendment claims and declining to address unpreserved due-process claims.

Issues

Issue	Plaintiff's Argument (Graham)	Defendant's Argument (State)	Held
Whether mandatory lifetime special sentence of parole for a juvenile is categorically cruel and unusual	Mandatory lifetime parole imposed without individualized youth-based sentencing is unconstitutional for juveniles	Lifetime special sentence is parole (not equivalent to LWOP), provides eligibility for early discharge and administrative modification	Denied — statute not categorically unconstitutional on this record; Graham not entitled to relief
Whether mandatory lifetime sex-offender registration for a juvenile is categorically cruel and unusual	Lifetime registration is punitive and disproportionate as applied to juveniles	Registration is regulatory; administrative remedies and prior precedent support constitutionality	Denied — no relief; claim not adequately developed below and registration not shown punitive on this record
Whether 2000-foot residency restriction is punitive/banishment as applied	2000-foot rule effectively banishes juveniles and is punitive	Rule is regulatory; constitutionality depends on particularized proof of harm	Denied — district court record lacked evidence of concrete injury or impact on Graham
Whether lifetime parole and registration are grossly disproportionate as applied (Bruegger claim)	Graham’s youth and rehabilitation make lifetime supervision grossly disproportionate	Parole conditions and potential for administrative discharge prevent gross disproportionality; record shows moderate risk factors	Denied — as-applied challenge fails on the present record; no showing parole conditions are grossly disproportionate

Key Cases Cited

State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (mandatory minimums require individualized youth-based consideration)
State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (categorical juvenile life-without-parole prohibition under Iowa law)
State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (Miller/Graham principles applied to juvenile sentencing)
State v. Null, 836 N.W.2d 41 (Iowa 2013) (juvenile sentencing requires consideration of youth characteristics)
State v. Bruegger, 773 N.W.2d 862 (Iowa 2009) (as-applied gross disproportionality framework)
State v. Lathrop, 781 N.W.2d 288 (Iowa 2010) (special lifetime parole is punishment for ex post facto analysis)
State v. Wade, 757 N.W.2d 618 (Iowa 2008) (special sentence review for gross disproportionality)
State v. Louisell, 865 N.W.2d 590 (Iowa 2015) (procedural limits on courts modifying special parole sentences; ripeness of parole claims)
State v. Boche, 885 N.W.2d 523 (Neb. 2016) (upholding individualized lifetime supervision under Eighth Amendment)
State v. Dull, 351 P.3d 641 (Kan. 2015) (holding mandatory lifetime postrelease supervision for juveniles unconstitutional)
Doe v. Miller, 298 F. Supp. 2d 844 (S.D. Iowa 2004) (district-court finding lifetime registration punitive based on developed evidentiary record)
Doe v. Miller, 405 F.3d 700 (8th Cir. 2005) (appellate reversal on punitive-character finding)