State of Iowa v. Daimonay Darice Richardson
2017 Iowa Sup. LEXIS 14
Iowa2017Background
- Defendant Daimonay Richardson was 15 when she aided and abetted the stabbing murder of Ronald Kunkle; she pled guilty to second-degree murder.
- District court sentenced her to an indeterminate term (not exceeding 50 years) and ordered mandatory restitution of $150,000 to the victim’s estate under Iowa Code § 910.3B.
- Richardson did not object at sentencing but appealed the restitution order, arguing (1) Iowa Code § 901.5(14) (2013) gave the court discretion to suspend or reduce mandatory minimums for juveniles (including restitution), and (2) § 910.3B’s $150,000 mandatory restitution is unconstitutional under article I, § 17 (excessive fines and cruel and unusual punishment), both facially and as applied.
- The court of appeals affirmed; the Iowa Supreme Court granted further review.
- The Supreme Court held § 901.5(14) does not authorize reducing mandatory restitution under § 910.3B, and upheld § 910.3B against both facial and as-applied challenges under article I, § 17.
Issues
| Issue | Plaintiff's Argument (Richardson) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether Iowa Code § 901.5(14) permits courts to reduce/suspend mandatory restitution under § 910.3B for juvenile offenders | § 901.5(14)’s reference to suspending "sentence" (including any mandatory minimum) includes restitution, so the court had discretion to reduce restitution for a juvenile | "Sentence" as used in § 901.5(14) concerns periods of confinement/fines at pronouncement of sentence and does not include restitution (which is governed by chapter 910 and may be set later) | Held: § 901.5(14) does not apply to § 910.3B restitution; trial court had no statutory discretion to lower the $150,000 minimum |
| Whether § 910.3B’s $150,000 mandatory restitution is facially unconstitutional under article I, § 17 (cruel and unusual / excessive fines) as applied to juveniles | Lyle/Miller line requires individualized consideration of youth; mandatory, one‑size‑fits‑all restitution for juveniles violates protections analogous to mandatory juvenile incarceration rulings | § 910.3B is a punitive monetary measure properly analyzed under the Excessive Fines Clause; restitution differs qualitatively from incarceration, is tied to death‑resulting felonies, is offset by civil recovery, and is payable under flexible plans | Held: § 910.3B is not facially unconstitutional under article I, § 17 (cruel-and-unusual not applicable to fines; excessive-fines analysis fails—$150,000 is not grossly disproportionate) |
| Whether § 910.3B’s mandatory restitution is cruel and unusual punishment for juveniles | Mandatory punishment without individualized youth consideration violates cruel and unusual protections (invoking Miller/Lyle) | Cruel-and-unusual clause addresses physical confinement and conditions; monetary penalties fall under Excessive Fines Clause, so Miller/Lyle do not compel invalidation under cruel-and-unusual | Held: Cruel and unusual clause is inapplicable to restitution; court analyzes under Excessive Fines Clause instead |
| Whether the $150,000 restitution was unconstitutional as‑applied to Richardson given her youth and background | Her age, history (abuse, coercion by older co‑defendant, trauma, substance use) reduce culpability and make the mandatory amount grossly disproportionate | The offense was extremely serious (intentional participation in a killing); restitution is creditable against civil recovery, not payable all at once, and payment plans/credit rules mitigate hardship | Held: As‑applied challenge fails on this record—the $150,000 is not grossly disproportionate to the offense; ability‑to‑pay or payment‑plan challenges are premature and must be pursued under statutory procedures |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (youthful offenders require individualized sentencing consideration; children are constitutionally different for sentencing)
- State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (Iowa precedent applying Miller to mandatory juvenile prison terms)
- State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (Miller factors discussion for juvenile sentencing)
- State v. Null, 836 N.W.2d 41 (Iowa 2013) (Miller‑line juvenile sentencing guidance)
- State v. Izzolena, 609 N.W.2d 541 (Iowa 2000) (upholding § 910.3B against excessive‑fines challenge for adults; restitution has punitive elements but $150,000 not grossly disproportionate)
- State v. Klawonn, 609 N.W.2d 515 (Iowa 2000) (§ 910.3B mandatory once felony conduct causes death; treatment of civil settlement credits against restitution)
- United States v. Bajakajian, 524 U.S. 321 (1998) (forfeiture/excessive‑fines test: gross disproportionality to gravity of offense)
- Paroline v. United States, 572 U.S. 434 (2014) (discussing punitive characteristics of restitution and Eighth Amendment considerations)