State of Iowa v. Khasif Rasheed White, 903 N.W.2d 331

Khasif White committed three second-degree robberies between Aug 2009 and Feb 2010 at age 17; he was sentenced in July 2010 to concurrent ten-year terms with a seven-year mandatory minimum before parole under Iowa Code § 902.12(5).
After State v. Lyle (2014) held mandatory juvenile parole-ineligibility unconstitutional absent individualized assessment, White was resentenced in April 2015 with a hearing to decide whether the seven-year bar should remain.
At the resentencing White and his mother testified; the State introduced a prison disciplinary summary showing numerous major reports and recent infractions while incarcerated.
The district court reinstated the seven-year parole ineligibility, reasoning White’s repeated juvenile offenses showed greater appreciation of consequences (greater maturity) and his prison record showed poor rehabilitation.
White appealed, arguing (1) the district court misapplied sentencing factors and improperly used his criminal and disciplinary history, and (2) the district court lacked authority to impose the statutory mandatory minimum because it is unconstitutional as applied to juveniles.
The Iowa Supreme Court reversed: it found the resentencing hearing failed to satisfy the requirements articulated in State v. Roby and vacated the court of appeals decision, remanding for resentencing under Roby’s framework.

Issue	Plaintiff's Argument (White)	Defendant's Argument (State)	Held
Did the district court properly apply juvenile sentencing factors at resentencing (abuse of discretion)?	Court failed to consider all relevant factors, mischaracterized family/home environment and juvenile status as mitigating, and misused prison disciplinary record.	District court properly weighed Miller/Ragland factors and permissibly relied on repeated offenses and in-prison disciplinary history.	Court held district court abused its discretion: resentencing was not grounded in juvenile brain science or expert evidence as required by Roby; remand for resentencing.
Did the district court lack authority to impose the mandatory minimum under Iowa Code § 902.12 as applied to juveniles?	The statute is unconstitutional as applied to juveniles.	The statute is valid if an individualized assessment hearing is held; Lyle requires such a hearing but did not invalidate the statute entirely.	Court rejected facial invalidity; § 902.12 is not void but requires individualized assessment; Lyle’s remedy is an individualized hearing.

State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (held mandatory juvenile parole-ineligibility unconstitutional without individualized hearing)
State v. Roby, 897 N.W.2d 127 (Iowa 2017) (established need for juvenile brain-science-informed analysis and expert testimony when imposing juvenile parole ineligibility)
State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (adopted Miller factors for juvenile sentencing analysis)
Miller v. Alabama, 567 U.S. 460 (2012) (juvenile offenders’ diminished culpability requires special sentencing considerations)
Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (life-without-parole for juveniles permissible only in rare cases reflecting permanent incorrigibility)
State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (discussed as an alternative approach to juvenile mandatory minimums)