State of Iowa v. Sayvon Andre Propps, 2017 Iowa Sup. LEXIS 60

Background

In 2011, Sayvon Propps (age 17) pleaded guilty to four counts of willful injury causing serious injury (forcible felony) after shooting Derek Carr; sentenced to four consecutive indeterminate terms not to exceed ten years (no mandatory minimums).
Because willful injury is a forcible felony, Iowa law barred deferred judgment/probation for Propps (Iowa Code § 907.3), though his indeterminate terms made him immediately parole-eligible.
In 2014 Propps filed a motion to correct an illegal sentence arguing the forcible-felony mandatory-incarceration rule violated the Iowa Constitution under evolving juvenile-sentencing principles (Miller line).
The district court denied relief; the court of appeals affirmed. The Iowa Supreme Court treated the appeal as a petition for certiorari and granted review.
The Supreme Court analyzed (1) whether § 907.3 is categorically unconstitutional as applied to juveniles, (2) whether Propps’s sentence is grossly disproportionate as applied, and (3) whether a Miller individualized sentencing hearing was required.

Issues

Issue	Plaintiff's Argument (Propps)	Defendant's Argument (State)	Held
Whether Iowa Code § 907.3 (forcible-felony bar on probation/deferred judgment) is unconstitutional as applied to juveniles under Iowa Const. art. I, § 17 (cruel and unusual)	§ 907.3 mandates incarceration (no judicial option for probation), so juveniles are denied individualized consideration required by Miller/Lyle	Indeterminate sentence with immediate parole eligibility provides a realistic, meaningful opportunity for release; legislature may categorically require incarceration for forcible felonies	§ 907.3 is not unconstitutional as applied to juveniles; statute survives categorical challenge
Whether Propps’s specific sentence (four consecutive indeterminate 0–10 year terms) is grossly disproportionate as applied	The aggregate long exposure to prison and lack of individualized sentencing rendered the punishment grossly disproportionate to his culpability as a juvenile	Sentence was relatively low-severity (indeterminate and immediately parole-eligible) compared to offense gravity; deference to legislature	No gross disproportionality: threshold inquiry fails; sentence upheld
Whether a Miller individualized sentencing hearing was required where there is no mandatory minimum and parole eligibility is immediate	Lyle should extend to any situation where sentencing statute removes judicial option to avoid incarceration (even if parole-eligible) — so Miller hearing required	Miller/Lyle apply to mandatory minimums and functional life-without-parole equivalents; not to indeterminate parole-eligible terms with no mandatory minimum	Court declines to extend Miller/Lyle to require a Miller hearing here; no individualized hearing required
Proper appellate procedure for challenging denial of motion to correct illegal sentence	N/A (procedural)	N/A (procedural)	Court treated the appeal as a petition for certiorari and granted review (motion-to-correct illegal sentence may be reviewed by certiorari/discretionary review)

Key Cases Cited

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles violates Eighth Amendment; requires individualized consideration of youth)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty for juveniles prohibited)
Graham v. Florida, 560 U.S. 48 (2010) (life without parole for nonhomicide juvenile offenders prohibited)
Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller substantive and retroactive)
State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (Miller applies retroactively; commuted juvenile life sentences require individualized sentencing)
State v. Null, 836 N.W.2d 41 (Iowa 2013) (lengthy term-of-years can trigger Miller protections; Roper/Graham/Miller principles not crime-specific)
State v. Pearson, 836 N.W.2d 88 (Iowa 2013) (minimum 35-year term triggered Miller hearing requirement)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (all mandatory minimums for juveniles unconstitutional under Iowa Constitution)
State v. Louisell, 865 N.W.2d 590 (Iowa 2015) (parole opportunity must be meaningful; parole-board factors may not fully capture youth attributes)
State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (categorical ban on juvenile life-without-parole; parole board better positioned to evaluate maturation/rehabilitation)
State v. Oliver, 812 N.W.2d 636 (Iowa 2012) (gross disproportionality analysis framework)
State v. Bruegger, 773 N.W.2d 862 (Iowa 2009) (procedural posture: appellate review of motions to correct illegal sentence)