Iowa Supreme Court Strikes Down Mandatory Minimum Sentences for Children


On July 18, 2014, the Iowa Supreme Court ruled that imposing mandatory minimum sentences on juvenile offenders is unconstitutional because “it fails to account for too much of what we know is child behavior.”

The case involved Andre Lyle, a seventeen-year-old high school student in Des Moines who punched another kid at school and took a bag of marijuana from him. He was convicted of second-degree burglary and sentenced to 25 years in prison with a mandatory minimum of 7 years to be served prior to becoming eligible for parole or work release.

On appeal, he argued that Iowa’s mandatory minimum sentencing scheme is unconstitutional as applied to juvenile offenders.

The Iowa Supreme Court agreed, reasoning that because “children are constitutionally different from adults for purposes of sentencing,” the sentencing judge must have discretion to consider youth and its attendant circumstances as a mitigating factor and to impose a lighter punishment. It vacated Andre’s sentence and remanded for the judge to consider a sentencing option other than imprisonment for his “inane juvenile schoolyard conduct.”

“Mandatory minimum sentences for juveniles are simply too punitive for what we know about juveniles.” Because we all know that children are immature, impulsive, vulnerable to negative influences, and have an inherent capacity for rehabilitation, sentences crafted for adults cannot be automatically applied to children. Instead, there must be some “assurance that imprisonment is actually appropriate and necessary” before sending a child to adult prison.

The court opined that most parents would be stunned to learn that Iowa’s mandatory sentencing scheme requires courts to imprison youthful offenders without looking into the details of the particular offense and the individual circumstances of the child. Indeed, “[t]here is no other area of the law in which our laws write off children based only on a category of conduct without considering all background facts and circumstances.”

The law requires that the sentencing judge consider the child’s youth and background and the circumstances of his conduct in order to determine the appropriate punishment. Accordingly, the court held, a “statute that sends all juvenile offenders to prison for a minimum period of time under all circumstances simply cannot satisfy the standards of decency and fairness embedded in article I, section 17 of the Iowa Constitution.”

The decision requires that all juvenile offenders who are in prison under Iowa’s mandatory sentencing scheme be returned to court for resentencing.