State of Iowa v. Noah Riley Crooks, 911 N.W.2d 153

Background

At age 13, Noah Crooks fatally shot his mother; he had no prior criminal record. The State filed a juvenile delinquency petition and sought waiver to prosecute him as a youthful offender in district court under Iowa Code §232.45(7) (2011).
The juvenile court found probable cause, concluded there were not reasonable prospects for rehabilitation before age 18, waived jurisdiction, and transferred the case to district court as a youthful offender.
A jury convicted Crooks of second-degree murder; under Iowa law the district court deferred sentencing and supervision returned to the juvenile court until he approached age 18.
After multi-year placement at the State Training School and periodic review, the district court held a hearing before Crooks's 18th birthday and sentenced him to an indeterminate term not to exceed 50 years with immediate parole eligibility (no mandatory minimum).
Crooks appealed arguing: (1) the statute did not authorize transferring a 13‑year‑old for youthful‑offender prosecution; (2) the waiver provision and §907.3A are cruel and unusual as applied to a 13‑year‑old; and (3) the district court abused its discretion in sentencing.

Issues

Issue	Plaintiff's Argument (Crooks)	Defendant's Argument (State)	Held
Whether §232.45(7)(a)(1) permits waiver of a 13‑year‑old to be prosecuted as a youthful offender	Statute ambiguous; read with related provisions it creates a 14‑year floor and thus cannot apply to 13‑year‑olds	Statute plainly includes "fifteen years of age or younger," which unambiguously encompasses 13‑year‑olds	Court: Statute unambiguous; juvenile court properly waived jurisdiction for a 13‑year‑old
Whether the waiver process under §232.45(7) constitutes "punishment" (cruel and unusual)	Waiver moves a child from rehabilitative juvenile system to adult system and thus is punitive	Waiver is procedural; youthful‑offender scheme contains individualized findings and safeguards and is not itself punishment	Court: Waiver is not punishment for art. I, §17; statute's individualized protections avoid categorical Eighth‑Amendment style bar
Whether §907.3A (post‑trial dispositions) and sentencing a 13‑year‑old as a youthful offender violates article I, §17 (categorical challenge)	Court should adopt categorical bar forbidding adult sentencing for crimes committed at age 13	Statutory scheme provides individualized post‑trial sentencing, deferred supervision until age 18, and parole opportunity — consistent with Miller/Lyle jurisprudence	Court: Declines categorical bar; statutes provide required individualized procedures; upholds constitutionality as applied
Whether the district court abused discretion in imposing an indeterminate 0–50 year sentence with immediate parole eligibility	Court failed to consider alternatives, did not apply Miller/Lyle factors on the record, and evidence did not support confinement	Court considered record, recognized options, declined mandatory minimum, and explained reasons; immediate parole eligibility satisfies Lyle/Propps requirements	Court: No abuse of discretion; sentence affirmed

Key Cases Cited

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles unconstitutional; individualized sentencing required)
Graham v. Florida, 560 U.S. 48 (2010) (life without parole for nonhomicide juvenile offenders unconstitutional)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for crimes committed under 18; juveniles are constitutionally different)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (Iowa requires individualized sentencing analysis for juveniles; struck down mandatory juvenile minimums)
State v. Propps, 897 N.W.2d 91 (Iowa 2017) (indeterminate sentence with immediate parole eligibility satisfies Lyle; no Miller hearing required when no mandatory minimum imposed)
State v. Null, 836 N.W.2d 41 (Iowa 2013) (juvenile sentencing principles require consideration of youth factors when mandatory minimums are imposed)
State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (categorical prohibition on life without parole for juveniles under Iowa Constitution)