Reason Foundation

Reason Foundation

Iowa Supreme Court Rules Mandatory Minimum Sentencing Statutes for Juveniles are Unconstitutional

Matt Hartill
July 29, 2014, 3:40pm

On July 18th, the Iowa Supreme Court issued a groundbreaking decision in Lyle v. State that prohibited the application of mandatory minimum sentencing statutes for individuals convicted as juveniles. Theruling has allowed Iowa to become the first state in the nation to prohibit these types of “tough on crime” sentences for children.

As a result of this ruling, roughly 100 offenders must now be resentenced, with consideration given to their age as well as other mitigating circumstances.

This particular case involved Andre Jerome Lyle Jr., who appealed his mandatory minimum sentence following his conviction for second-degree robbery. After taking a small plastic bag containing $5 worth of marijuana from a fellow student in October 2010, Lyle was not only charged as an adult, but was sentenced to a mandatory minimum of ten years of imprisonment. Under Iowa law, he was also required to serve 70 percent of his sentence before becoming eligible for parole.

In the July 18th ruling, the Iowa Supreme Court ruled statutes that mandate minimum terms of imprisonment for juveniles with no opportunity for parole until a minimum portion of the term is served are unconstitutional under the Iowa Constitution. As such, the court vacated Lyle’s sentence and ordered for him to be resentenced by a district court.

The opinion cites the 2012 United States Supreme Court decision, Miller v. Alabama, which prohibited mandatory life imprisonment without parole for juveniles convicted of first-degree murder. A pair of 2013 Iowa Supreme Court rulings—State v. Null and State v. Pearsonalso contributed to the court's legal reasoning in this case, as these rulings declared juveniles could not be sentenced to mandatory terms of imprisonment without the possibility of parole.

In addition to these past rulings, the Iowa Supreme Court considered two factors—juveniles’ lack of risk-calculation skills and the state’s interest in supporting the best interests of juveniles— as being especially important to this ruling. Iowa Supreme Court Chief Justice Mark Cady, who authored the opinion, clarifies the decision saying: “The constitutional analysis is not about excusing juvenile behavior, but imposing punishment in a way that is consistent with our understanding of humanity today.” That is exactly what stands out about the Iowa decision: it represents solid legal reasoning along with an understanding of a changing political climate.

Unfortunately, juveniles can still receive excessively harsh punishments in Iowa; this ruling simply prevents judges from doling out sentence lengths mandatorily.

Nevertheless, the State v. Lyle opinion illustrates a creative and thoughtful interpretation of past precedent and marks an important departure from “tough-on-crime” legislation for juveniles. Hopefully other states will follow Iowa’s lead, by promoting smarter sentencing policy in the future.

Matt Hartill is Policy Intern

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