State of Iowa v. Kenneth Owen Barry, 16-0055

Kenneth Barry (age 16 at offense; ~18 at sentencing) pled guilty to two counts of second-degree robbery and one count of conspiracy; sentenced to concurrent 10-year terms on robbery counts, consecutive to conspiracy, totaling up to 20 years.
Sentencing included a mandatory parole-ineligibility minimum: seven years on the robbery counts per Iowa Code § 902.12(1) (70% of maximum).
More than a year after sentencing, Barry moved to correct an illegal sentence under State v. Lyle, arguing the mandatory minimum made his sentence illegal and required resentencing.
At sentencing the district court made an individualized record addressing juvenile-sentencing factors (age/youthful features, family background, offense circumstances including weapon use, rehabilitation prospects, juvenile history), and expressly found the mandatory minimum warranted.
The district court denied Barry’s motion; on appeal the Iowa Court of Appeals affirmed, holding the sentence was not illegal because the court had considered the Miller/Lyle factors before imposing the mandatory minimum.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Barry’s sentence is illegal because it includes a mandatory minimum parole-ineligibility term for a juvenile	State: Sentence legal because district court performed individualized juvenile sentencing analysis and law permits juvenile mandatory minimums when justified	Barry: Lyle requires resentencing of all juveniles serving mandatory minimums; his sentence is illegal and needs resentencing	Court: Denied — not illegal; Lyle requires resentencing only where no individualized Miller/Lyle analysis occurred, but here the court had considered the required factors

State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (held mandatory parole-ineligibility minimums for juveniles violate Iowa Constitution unless individualized factors are considered)
Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (juvenile life-without-parole requires consideration of youth-related mitigating factors)
State v. Null, 836 N.W.2d 41 (Iowa 2013) (explained application of Miller factors under Iowa law)
State v. Pearson, 836 N.W.2d 88 (Iowa 2013) (juvenile sentencing guidance recognizing youth-related mitigating factors)
State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (juvenile sentencing factors and analysis)
Roper v. Simmons, 543 U.S. 551 (2005) (juveniles are constitutionally different for sentencing purposes)
Graham v. Florida, 560 U.S. 48 (2010) (barred life without parole for nonhomicide juvenile offenders)