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