Iowa Supreme Court Holds Miller Decision Is Fully Retroactive


The Iowa Supreme Court today held that the United States Supreme Court’s 2012 decision in Miller v. Alabama barring mandatory life imprisonment without parole sentences for children applies retroactively to cases on collateral review and “to sentences that are the functional equivalent of life without parole.”

Some Iowa prosecutors argued that the Miller decision does not apply to people who were automatically sentenced to die in prison for juvenile offenses if they had completed the direct appeal process before the decision was announced last year.

In a unanimous decision, the state’s highest court rejected that argument, reasoning that the procedural requirement for an individualized sentencing hearing for juveniles “is the result of a substantive change in the law that prohibits mandatory life-without-parole sentencing.” Citing decisions from Illinois, Louisiana, and Mississippi, the court held that, Miller “bars states from imposing a certain type of punishment on certain people,” and applies retroactively.

The State also argued that Miller does not apply because the Iowa Governor last year commuted all juvenile life-without-parole sentences to terms of imprisonment for life with the possibility of parole after serving 60 years. The court chose not to address the constitutionality of the governor’s action and instead held that the commuted sentence, which proscribed parole for defendant Jeffrey Ragland until age 78, amounts to mandatory life without parole for the purposes of Miller.

The “unconstitutional imposition of a mandatory life-without-parole sentence is not fixed by substituting it with a sentence with parole that is the practical equivalent of a life sentence without parole,” the court wrote. “Oftentimes, it is important that the spirit of the law not be lost in the application of the law. This is one such time.”

“In the end,” the court concluded, “a government system that resolves disputes could hardly call itself a system of justice with a rule that demands individualized sentencing considerations common to all youths apply only to those youths facing a sentence of life without parole and not to those youths facing a sentence of life with no parole until age seventy-eight. Accordingly, we hold Miller applies to sentences that are the functional equivalent of life without parole. The commuted sentence in this case is the functional equivalent of a life sentence without parole.”

In two separate decisions issued today, the court ordered individualized resentencing for two other juveniles, Denem Anthony Null, who was sentenced to more than 52 years for murder and robbery when he was 16, and Desirae Monique Pearson, who was sentenced to 35 years without parole for robbery and burglary when she was 17.