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State of Iowa v. Morris Lee Parson, Jr.
16-2067
| Iowa Ct. App. | Jul 19, 2017
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Background

  • In May 2016 Parson shook his girlfriend’s five‑month‑old infant several times; the child suffered a life‑threatening bilateral subdural hematoma and other acute symptoms.
  • Parson was charged with child endangerment causing serious injury and neglect of a dependent; he pleaded guilty to child endangerment causing bodily injury (a lesser included) and neglect of a dependent.
  • At sentencing the court considered the PSI (excluding dismissed charges), letters from family, Parson’s age, prior record (including juvenile adjudications), employment and family circumstances, and the nature/circumstances of the offenses.
  • The court sentenced Parson to an indeterminate five years on count I and ten years on count II, to run concurrently (total exposure not to exceed ten years); probation was denied.
  • Parson appealed, arguing the court used boilerplate sentencing language and improperly considered juvenile adjudications without addressing youth‑related mitigating factors.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the sentencing court failed to consider required statutory factors (used "boilerplate") State: court adequately considered relevant factors and PSI and explained reasons sufficiently Parson: court relied on boilerplate language and did not meaningfully weigh statutory factors Held: No abuse of discretion; court gave a cursory, adequate explanation and considered the listed factors
Whether juvenile adjudications were improperly considered at sentencing without juvenile mitigating analysis State: juvenile adjudications are admissible and court may consider them under statute Parson: if juvenile adjudications used, court must consider youth‑related mitigating factors Held: Iowa Code authorizes consideration of juvenile adjudications; court did not abuse discretion in using them

Key Cases Cited

  • State v. Hill, 878 N.W.2d 269 (Iowa 2016) (standard for reviewing sentencing for abuse of discretion)
  • State v. Putman, 848 N.W.2d 1 (Iowa 2014) (when sentencing is untenable)
  • State v. Thacker, 862 N.W.2d 402 (Iowa 2015) (statutory sentencing factors)
  • State v. Johnson, 476 N.W.2d 330 (Iowa 1991) (nature of offense and defendant characteristics as sentencing factors)
  • State v. Barnes, 791 N.W.2d 817 (Iowa 2010) (requirement for at least cursory on‑the‑record explanation)
  • State v. Jacobs, 607 N.W.2d 679 (Iowa 2000) (same)
  • State v. Lyle, 854 N.W.2d 678 (Iowa 2014) (discussion of mitigating factors for youthful offenders)
Read the full case

Case Details

Case Name: State of Iowa v. Morris Lee Parson, Jr.
Court Name: Court of Appeals of Iowa
Date Published: Jul 19, 2017
Docket Number: 16-2067
Court Abbreviation: Iowa Ct. App.