State of Iowa v. Shawn Eric Pattison, 16-0950

Background

Shawn Pattison was convicted of possession of methamphetamine (.41 grams) in 2015 and admitted at least two prior felony convictions and prior drug convictions dating back to 1999–2009.
Charged under Iowa Code §124.401(5) as possession, third-or-subsequent offense (class D felony), and the State alleged habitual offender status under Iowa Code §902.9.
The district court imposed an indeterminate 15-year sentence under the habitual-offender statute with a mandatory minimum parole ineligibility of three years under §902.8.
On appeal Pattison challenged only the constitutionality of the sentence under the Iowa Constitution (due process and cruel and unusual punishment).
The court reviewed constitutional questions de novo but afforded strong deference to legislative sentencing choices, applying Iowa precedent on recidivist sentencing and proportionality.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether applying the habitual-offender statute to a repeat drug user violates substantive due process	State: legislature may punish recidivists to deter/incapacitate; statute serves legitimate goals	Pattison: as a drug user (not dealer), he should receive lenient, treatment-focused sentencing; enhanced incarceration violates due process	Court: no due process violation; enhanced punishment for recidivism has a rational fit with deterrence/incapacitation objectives
Whether the 15-year sentence is categorically cruel and unusual under Iowa Const. art. I, §17	State: recidivist statutes reflect national consensus favoring harsher penalties for repeat offenders	Pattison: legislative trend toward treatment for drug users shows societal standard for leniency; 15 years for a rock of meth is excessive	Court: not categorically cruel; recidivist nature increases culpability and supports enhancement
Whether the sentence is grossly disproportionate (Solem/Ewing test)	State: defendant’s long criminal history justifies deference to legislature and longer sentence	Pattison: 15 years for possession of .41g is grossly disproportionate given the minor quantity and user status	Court: threshold comparison fails to show gross disproportionality; no need to proceed further; sentence upheld
Whether any unusual features of the case create a high risk of disproportionality	State: no unusual combination of features; typical recidivist profile	Pattison: argues quantity and status as user create unjust combination	Court: no unusual combination; defendant’s recidivism controls; sentence not cruel or excessive

Key Cases Cited

State v. Bruegger, 773 N.W.2d 862 (Iowa 2009) (proportionality review and deference to legislative sentencing)
State v. Lara, 580 N.W.2d 783 (Iowa 1998) (strong presumption of constitutionality for legislative prison terms)
State v. Kramer, 235 N.W.2d 114 (Iowa 1975) (statute upheld unless clearly and palpably violative of constitution)
State v. Kingery, 774 N.W.2d 309 (Iowa 2009) (reasonable-fit standard for substantive due process in sentencing)
State v. Maxwell, 743 N.W.2d 185 (Iowa 2008) (legitimate interest in deterring and punishing incorrigible offenders)
State v. Oliver, 812 N.W.2d 636 (Iowa 2012) (recidivism as basis for increased punishment and consideration of offender culpability)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (categorical cruel-and-unusual analysis and independent review)
Solem v. Helm, 463 U.S. 277 (U.S. 1983) (gross-disproportionality test framework)
Ewing v. California, 538 U.S. 11 (U.S. 2003) (modification of Solem factors for proportionality review)