The Iowa Supreme Court today adopted a categorical rule that juvenile offenders may not be sentenced to life without the possibility of parole.
The decision in State v. Sweet extends the United States Supreme Court’s decision in Miller v. Alabama, which struck down mandatory life-without-parole sentences for children.
Miller prevents courts from imposing life without parole in most homicide cases involving juveniles, the Iowa Supreme Court explained. “[T]he Supreme Court has already established that except in very rare cases, life without the possibility of parole is not available under the Federal Constitution even for heinous crimes committed by juvenile offenders.” Accordingly, life-without-parole cannot be imposed unless the prosecution proves the juvenile is one of the “extremely rare” juveniles who is “irredeemably corrupt.”
In today’s decision, the court determined that the Iowa Constitution requires a categorical rule barring all life-without-parole sentences for children because it is “simply too speculative and likely impossible” to identify which juvenile offenders are “irretrievable” at the time of trial.
“[G]iven what we now know about the timeline of brain development and related prospects for self-regulation and rehabilitation,” the court reasoned, a trial judge cannot be expected to “identify with assurance those very few adolescent offenders that might later be proven to be irretrievably depraved.” The court pointed out that “even trained professionals with years of clinical experience would not attempt to make such a determination.”
“[S]entencing courts should not be required to make speculative up-front decisions on juvenile offenders’ prospects for rehabilitation because they lack adequate predictive information supporting such a decision,” the court decided. “The parole board will be better able to discern whether the offender is irreparably corrupt after time has passed, after opportunities for maturation and rehabilitation have been provided, and after a record of success or failure in the rehabilitative process is available.”
While juvenile offenders are not guaranteed parole, the court concluded that “[t]he determination of irredeemable corruption . . . must be made when the information is available to make that determination and not at a time when the juvenile character is a work in progress.”
Iowa now joins a growing number of states that have abolished death-in-prison sentences for children after Miller. Utah, South Dakota, Hawaii, Connecticut, West Virginia, Delaware, Nevada, Vermont, Wyoming, and Texas also have eliminated death-in-prison sentences for children in recent years.