State of Iowa v. Jimmy Lee Allen, 16-0095

Jimmy Lee Allen was convicted of first-degree murder for a 1982 killing and sentenced to life without parole; conviction was affirmed on direct appeal.
At trial the State proved Allen participated in a plan to rob and kill the victim; victim died of multiple stab wounds and blunt trauma.
Allen was 21 years, 10 months old at the time of the offense and challenges his mandatory life-without-parole sentence as cruel and unusual for offenders under 25.
He filed a motion to correct an illegal sentence arguing Eighth Amendment and Iowa Constitution violations based on youth-related neuroscience and recent juvenile-sentencing precedent.
Allen separately sought return of $1,214.40 from his inmate account (attorney fees), which the district court dismissed; he renewed restitution-related arguments that had been litigated previously.
The district court denied the motion to correct sentence and rejected the restitution claim; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandatory life without parole for a 21-year-old is cruel and unusual	State: statutory mandatory sentence for class A murder is constitutional	Allen: life without parole for offenders under 25 is disproportionate given youth development research; categorical challenge like Sweet/Lyle should apply	Rejected: Lyle and Sweet apply to juveniles; no extension to adult offenders; sentence not illegal
Whether sentencing hearing required to consider youth for adult offenders	State: statutory sentencing for adults controls; no hearing required	Allen: maturity continues into early adulthood, so a hearing or delayed parole eligibility should be required	Rejected: Lyle limits required youth-focused procedures to under-18 offenders; court declines to alter established adult sentencing rules
Whether prior restitution/account claim can be relitigated	State: restitution order stands; prior appeals resolved issues	Allen: seeks return of funds from inmate account	Rejected: claim barred by law of the case and prior rulings; cannot relitigate postconviction matters

State v. Allen, 348 N.W.2d 243 (Iowa 1984) (background facts and direct-appeal affirmance of conviction)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (required sentencing consideration for juvenile offenders; holding limited to under-18 defendants)
State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (categorical rule: juveniles cannot receive life without parole under Iowa Constitution)
State v. Bruegger, 773 N.W.2d 862 (Iowa 2009) (illegal-sentence claims reviewed without preservation rules)
State v. Jose, 636 N.W.2d 38 (Iowa 2001) (standard of review for restitution orders)