State v. Sweet
2016 Iowa Sup. LEXIS 64
| Iowa | 2016

Background

  • In May 2012, 17-year-old Isaiah Sweet shot and killed his grandparents; he later pleaded guilty to two counts of first-degree murder.
  • At sentencing the district court reviewed a PSI, victim impact statements, juvenile records, and expert testimony (Dr. Stephen Hart) about Sweet’s developmental, mental-health, and behavioral history.
  • The district court found the murders premeditated and the case "rare," and sentenced Sweet to life without parole (LWOP).
  • Sweet appealed, arguing LWOP for a juvenile is unconstitutional under article I, § 17 of the Iowa Constitution (and relying on federal Eighth Amendment precedents).
  • The State defended the sentence as a proper individualized Miller-type analysis showing irretrievable corruption.
  • The Iowa Supreme Court reversed: it held that under the Iowa Constitution LWOP is categorically barred for juvenile offenders and remanded for resentencing (life with parole remains permissible).

Issues

Issue Plaintiff's Argument (Sweet) Defendant's Argument (State) Held
Whether a juvenile may be sentenced to LWOP under the Iowa Constitution LWOP is unconstitutional for juveniles; youth features (immaturity, family, impulsivity, poor prediction of future conduct) make categorical ban necessary Miller factors applied individually can identify the rare irretrievably corrupt juvenile; sentencing court properly applied factors here Held: LWOP for juveniles is categorically prohibited under Iowa Const. art. I, § 17; sentence vacated and resentencing ordered
If not categorical, whether the district court’s individualized Miller analysis justified LWOP in this case The district court’s findings do not overcome the presumption against LWOP for juveniles; predictive judgments are unreliable The crimes were premeditated, horrific, and show enduring dangerousness; individualized hearing supported LWOP Court rejected as-applied justification because it adopted categorical rule; remanded for resentencing consistent with ban
Role of parole board vs. sentencing court in assessing irretrievability Juvenile irretrievability should be assessed after maturation; parole board is better situated to evaluate rehabilitation over time Sentencing court can and should make individualized, immediate determinations using Miller factors Held: determination of permanent denial of parole should not be made at initial sentencing; postconviction/parole processes can address irretrievability
Standard of review for Miller-type claims (Sweet) constitutional claims reviewed de novo (State) N/A on standard; defends substantive ruling below Court: de novo review; reached constitutional holding and vacated LWOP sentence

Key Cases Cited

  • Weems v. United States, 217 U.S. 349 (1910) (Eighth Amendment proportionality and evolving standards principle)
  • Trop v. Dulles, 356 U.S. 86 (1958) (Evolving standards of decency guide Eighth Amendment)
  • Furman v. Georgia, 408 U.S. 238 (1972) (death-penalty arbitrariness concerns)
  • Gregg v. Georgia, 428 U.S. 153 (1976) (procedural safeguards can render capital punishment constitutional)
  • Woodson v. North Carolina, 428 U.S. 280 (1976) (mandatory death penalty unconstitutional; need for individualized sentencing)
  • Coker v. Georgia, 433 U.S. 584 (1977) (categorical Eighth Amendment bar for death in certain nonhomicide cases)
  • Enmund v. Florida, 458 U.S. 782 (1982) (death penalty barred for aider/abettor lacking intent to kill)
  • Eddings v. Oklahoma, 455 U.S. 104 (1982) (youth and emotional disturbance are mitigating at capital sentencing)
  • Thompson v. Oklahoma, 487 U.S. 815 (1988) (plurality limiting death eligibility for very young juveniles)
  • Penry v. Lynaugh, 492 U.S. 302 (1989) (individualized sentencing and consideration of mental characteristics required)
  • Stanford v. Kentucky, 492 U.S. 361 (1989) (upholding execution of 16–17 year olds under then-prevailing standards)
  • Atkins v. Virginia, 536 U.S. 304 (2002) (categorical Eighth Amendment bar to death for intellectually disabled)
  • Roper v. Simmons, 543 U.S. 551 (2005) (categorical bar to death penalty for juveniles)
  • Graham v. Florida, 560 U.S. 48 (2010) (categorical bar to LWOP for juveniles convicted of nonhomicide offenses)
  • Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles unconstitutional; require individualized consideration of youth)
  • Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller substantive rule applies retroactively; Miller bars LWOP for all but the rare juvenile whose crime reflects permanent incorrigibility)
  • State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (applying Miller factors; individualized hearing required)
  • State v. Null, 836 N.W.2d 41 (Iowa 2013) (applying Miller principles under Iowa Constitution)
  • State v. Pearson, 836 N.W.2d 88 (Iowa 2013) (treating youth traits as mitigating)
  • State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (extending Miller principles to other juvenile sentencing contexts)
  • State v. Seats, 865 N.W.2d 545 (Iowa 2015) (presumption for parole-eligible life sentences for juveniles; Miller requires careful consideration)
  • State v. Louisell, 865 N.W.2d 590 (Iowa 2015) (post-sentence rehabilitation evidence relevant to parole and sentencing)
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