State of Iowa v. Denem Null, 15-0833

Null, a minor, pled guilty to murder in the second degree and robbery in the first degree.
Original sentences were 50 years (murder) and 25 years (robbery), to run consecutively with a seven-tenths mandatory minimum.
Supreme Court overruled prior precedent; Null was resentenced to the same consecutive terms but without the mandatory minimum.
Null appealed asserting abuse of discretion and cruel and unusual punishment under the Iowa Constitution.
Null also argued Iowa Code section 902.4 does not apply to juveniles, seeking broader reconsideration rights.
The court vacated the consecutive-sentencing portion for lack of explicit reasons and remanded to decide consecutive vs concurrent with proper explanation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the consecutive sentences constitute abuse of discretion or cruel and unusual punishment.	Null argues consecutive terms are excessive.	Null contends Miller factors negate necessity of consecutive terms.	Consecutive sentences not cruel/unusual given Miller factors and parole opportunity; but remanded for explicit reasoning on consecutiveness.
Whether the district court failed to state reasons for consecutive sentences after Hill.	State argues reasons were implicit in original record.	Null contends no explicit reasons were provided at resentencing.	Vacate the consecutive-sentence portion; remand to articulate reasons for consecutive or concurrent sentences.
Whether Iowa Code section 902.4 applies to juveniles and allows additional reconsideration.	Null seeks interpretation to broaden reconsideration rights for juveniles.	Statutory interpretation restricted to plain meaning; not extended to juveniles.	Decline to interpret 902.4 to favor extended juvenile reconsideration; statute applied as written.

Miller v. Alabama, 132 S. Ct. 2455 ((Supreme Court, 2012)) (mandatory nature of juvenile life sentences unconstitutional; factors matter, not length alone)
Graham v. Florida, 560 U.S. 48 ((S. Ct. 2010)) (juvenile sentencing and meaningful opportunity for release)
State v. Hill, 878 N.W.2d 269 ((Iowa 2016)) (require explicit reasons for consecutive sentences; Miller factors used)
State v. Lyle, 854 N.W.2d 378 ((Iowa 2014)) (juvenile sentencing not prohibited to long terms absent mandatory minimums)
State v. Formaro, 638 N.W.2d 720 ((Iowa 2002)) (strong presumption of regularity in sentencing with need for clear reasons)
State v. Delaney, 526 N.W.2d 170 ((Iowa Ct. App. 1994)) (look to entire record to find supporting reasons for consecutive sentences)