State of Iowa v. Jarrod Dale Majors, 940 N.W.2d 372

Background

In 2002, Jarrod Majors (age 17, 15 days shy of 18) broke into the Peckham home, hid in a closet, threatened Hollie Peckham with a rifle and knife, and was subdued; he pled guilty to attempted murder and was originally sentenced to 25 years with a 17.5-year mandatory minimum before parole eligibility.
Following Iowa decisions limiting mandatory juvenile minimums (Lyle), Majors obtained resentencing in 2014 but was again given the same 17.5-year mandatory minimum; this Court reversed and remanded in light of Roby, directing an individualized youth-factor analysis supported by expert evidence when imposing minimums.
At Majors’ second resentencing (2018) the State called Dr. Theresa Clemmons (DOC psychiatrist) to apply the Miller/Lyle/Roby youth-factors; Majors declined to retain a defense expert after consulting counsel and the court.
The district court reviewed the five youth-focused factors (age/maturity; family/home; circumstances of the crime; ability to navigate process; capacity for rehabilitation), credited the State’s expert and prior Oakdale evaluation, and again imposed the 17.5-year mandatory minimum to be served before parole eligibility.
Majors appealed, arguing (1) the district court misapplied Roby and abused its discretion in imposing the mandatory minimum, and (2) trial counsel was ineffective for failing to present a defense expert on youth sentencing factors. The Iowa Supreme Court retained the appeal.
The majority affirmed: it found the court conducted the individualized Roby analysis supported by expert testimony and that counsel’s performance was not constitutionally deficient because Majors personally declined a defense expert and counsel reasonably relied on cross-examination.

Issues

Issue	Plaintiff's Argument (Majors)	Defendant's Argument (State)	Held
Whether the district court abused its discretion by imposing a 17.5-year mandatory minimum at second resentencing under Roby/Lyle/Miller	Court failed to follow Roby’s mandate and improperly treated Majors (age 17) as nearly adult; expert evidence was inadequate and court misapplied "children are different" framework	Court properly conducted individualized Roby analysis, relied on State expert and contemporaneous Oakdale evaluation, and statutory sentence was supported by evidence	No abuse of discretion; sentence affirmed
Whether defense counsel was ineffective for not presenting a defense expert on the youth factors	Failure to call a child-development expert was a breach of duty that prejudiced Majors’ resentencing outcome	Majors personally chose not to retain an expert; counsel’s strategy to rely on cross-examination was reasonable	No ineffective assistance: Majors’ decision and counsel’s strategy preclude relief

Key Cases Cited

State v. Roby, 897 N.W.2d 127 (Iowa 2017) (requires individualized Miller/Lyle youth-factor analysis and normally expert support when imposing juvenile mandatory minimums)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (automatic mandatory minimums for youthful offenders violate the Iowa Constitution; courts must consider youth factors)
Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (juveniles are constitutionally different; sentencing must account for youth-related mitigating factors)
State v. Goodwin, 936 N.W.2d 634 (Iowa 2019) (upheld a juvenile mandatory minimum after individualized hearing and expert support; courts may consider penological goals)
State v. Seats, 865 N.W.2d 545 (Iowa 2015) (discusses burden and individualized hearing for juvenile mandatory adult sentences)
Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (death penalty for juveniles unconstitutional; establishes that children are different for Eighth Amendment analysis)
Graham v. Florida, 560 U.S. 48 (U.S. 2010) (life without parole for nonhomicide juvenile offenders violates Eighth Amendment; emphasizes diminished juvenile culpability and rehabilitation)
State v. Null, 836 N.W.2d 41 (Iowa 2013) (recognizes continued brain development into early twenties and the special considerations for juvenile offenders)
State v. Louisell, 865 N.W.2d 590 (Iowa 2015) (affirmed reduced/parole-eligible sentence where long incarceration showed rehabilitation)
State v. Formaro, 638 N.W.2d 720 (Iowa 2002) (general standard on appellate review of sentencing for abuse of discretion)