State of Iowa v. Shannon Elizabeth Lee Breeden, 14

In 2003 Shannon Breeden (age 16 at offense) pleaded guilty to attempted murder after participating in a deadly assault and was sentenced to up to 25 years and ordered to pay $150,000 restitution to the victim’s estate under Iowa Code § 910.3B(1).
At sentencing the 85% mandatory minimum for forcible felonies was applied; that mandatory minimum later was held unconstitutional for juveniles and Breeden sought resentencing.
In 2014 the district court vacated the mandatory-minimum portion of her sentence, resentenced her with immediate parole eligibility, but reimposed the $150,000 restitution; Breeden did not object at that hearing.
Breeden appealed only the restitution order, arguing (1) Iowa Code § 901.5(14) (2013) allowed the court discretion to reduce restitution and (2) § 910.3B’s mandatory $150,000 restitution is unconstitutional—both facially as to juvenile offenders and as applied to her circumstances.
The Court of Appeals rejected Breeden’s contentions; the Iowa Supreme Court affirmed, relying in part on its contemporaneous decision in State v. Richardson and precedent addressing juvenile-sentencing principles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 901.5(14) gives sentencing courts discretion to reduce restitution mandated by § 910.3B	Breeden: § 901.5(14) permits the court to impose less restitution at resentencing	State: “sentence” in § 901.5(14) does not encompass restitution; § 910.3B mandates the $150,000 amount	No — § 901.5(14) does not alter § 910.3B; mandatory $150,000 remains applicable
Facial challenge: Is mandatory $150,000 restitution for juvenile homicide offenders unconstitutional under Iowa Const. art. I, § 17?	Breeden: statute is facially excessive for juveniles given Miller-era juvenile protections	State: restitution is remedial, tied to harm, and not at issue in Miller jurisprudence	No — statute is not facially unconstitutional
As-applied challenge: Is $150,000 excessive given Breeden’s youth, background, and role?	Breeden: her age, abuse history, and lesser culpability make the mandatory amount disproportionate	State: facts show serious, intentional conduct (admitted participation and intent to kill); restitution relates to harm	No — on this record the $150,000 restitution is not an excessive fine as applied to Breeden
Challenge based on payment plan or ability to pay	Breeden implied that application might be punitive given payment burden	State: payment plan issue not before court on this record	Court did not decide constitutionality based on payment plan or ability-to-pay; those issues remain open

State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (juvenile mandatory-minimum incarceration ruled unconstitutional in part)
State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (framework for considering Miller factors at juvenile resentencing)
Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles unconstitutional; requires consideration of youth)
State v. Calvin, 839 N.W.2d 181 (Iowa 2013) (standard of review for statutory sentencing questions)
State v. Pearson, 836 N.W.2d 88 (Iowa 2013) (juvenile sentencing considerations)
State v. Null, 836 N.W.2d 41 (Iowa 2013) (juvenile sentencing considerations)