Background

• Ragland, a juvenile, was convicted in 1986 of first‑degree murder for participation in a fatal fight; the conviction was under a felony‑murder theory relying on a willful injury predicate.
• He received life in prison without the possibility of parole, as required by statute.
• Ragland challenged the conviction on direct appeal arguing merger and due process concerns, which this Court rejected in 1988 (later overruled by Heemstra in 2006).
• Ragland pursued multiple state and federal actions; the district court and court of appeals dismissed, applying law of the case and res judicata, and preserving no merits review of conviction issues.
• In 2010 Ragland filed an application for correction of sentence alleging the sentence was cruel and unusual punishment; the district court dismissed it as barred by law of the case and res judicata, and the court of appeals affirmed without addressing merits.
• The Supreme Court vacated the court of appeals’ decision on the sentence issue, held law of the case bars conviction challenges but not sentence challenges, and remanded for consideration of the illegal-sentence claim in light of Veal/Bruegger and Graham.

Issues

Key Cases Cited

• Heemstra v. State, 721 N.W.2d 549 (Iowa 2006) (if willful injury causes death, cannot serve as predicate for felony‑murder)
• Veal v. State, 779 N.W.2d 63 (Iowa 2010) (cruel and unusual punishment challenge to life without parole is an illegal-sentence challenge)
• Bruegger v. State, 773 N.W.2d 862 (Iowa 2009) (allows challenge to life-without-parole sentence as applied under Iowa Constitution)
• Graham v. Florida, 560 U.S. 48 (U.S. 2010) (juvenile life-without-parole standards; categorical/gross proportionality approaches)
• Goosman v. State, 764 N.W.2d 539 (Iowa 2009) (retroactivity of Heemstra not established)
• State v. Grosvenor, 402 N.W.2d 402 (Iowa 1987) (law-of-the-case concept and its limitations)