State of Iowa v. Desirae Monique Pearson
2013 Iowa Sup. LEXIS 95
| Iowa | 2013Background
- Desirae Pearson, age 17, convicted by jury of two counts each of first-degree robbery and first-degree burglary at two separate homes on Thanksgiving night 2010.
- Sentencing stacked per transaction: concurrent sentences for each robbery/burglary pair, but the four sentences run consecutively to total 50 years with no parole eligibility until 35 years.
- Pearson’s crimes included using BB guns and injuring a victim; possessions looted included cash and electronic items.
- District court acknowledged Pearson’s youth but imposed a 50-year term without parole, emphasizing public protection over rehabilitation.
- Court of Appeals upheld the sentence, but the Iowa Supreme Court granted review to assess Eighth Amendment and Iowa Constitution challenges to a juvenile sentence without parole.
- The Supreme Court vacated the sentence and remanded for Miller/Null-based individualized sentencing analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pearson’s sentence without parole for juveniles is cruel and unusual. | Pearson argues 70% minimums and 35-year parole-ineligibility are disproportionate. | State contends sentence not grossly disproportionate under Miller/Null and deference to legislature. | Sentence vacated; remanded for Miller-based individualized reconsideration. |
| Applicability of Miller v. Alabama and related cases to this non-LWOP juvenile case. | Nulling Miller/ Graham applicability to Pearson’s long sentence. | Legislative and jurisprudential framework supports the sentence; Miller/Null control review. | Court adopts Miller/Null framework for juveniles and requires individualized findings on remand. |
| Whether the 70% mandatory minimums and consecutive structure violate proportionality. | Seventy-percent mins and consecutive terms produce excessive punishment. | Such terms reflect serious crimes and age near adulthood; proportionality not shown. | Remand to apply Miller standards; proportionality not definitively resolved in this opinion. |
| Whether the district court adequately considered rehabilitation and youth when sentencing. | Court treated rehabilitation as irrelevant. | Rehabilitation acknowledged but not sufficiently weighed. | Remand to incorporate Miller-based rehabilitation considerations. |
| Whether a separate issue on consecutive sentencing constitutes sentencing discretion abuse. | Not raised on appeal; potential abuse possible. | Unaddressed in record; need remand for complete review. | Not resolved; addressed on remand if necessary. |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (2010) (juveniles and meaningful opportunity to release; life-without-parole rule focus)
- Roper v. Simmons, 543 U.S. 551 (2005) (juvenile culpability and maturation considerations)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory LWOP for juveniles; strictures on age-based sentencing)
- Graham v. Florida (Graham line cited within Iowa context), 176 L. Ed. 2d 825 (2010) (explicates meaningful opportunity for release; not universal for all crimes)
- State v. Null, 836 N.W.2d 41 (2013) (Iowa 2013; Miller/Null framework applied to non-LWOP juvenile cases)
- State v. Bruegger, 773 N.W.2d 862 (2009) (proportionality analysis for sentences under Bruegger/Oliver framework)
- State v. Oliver, 812 N.W.2d 636 (2012) (proportionality review in Iowa for challenged sentences)