The Court ruled in Iowa v. Null, Iowa v. Pearson and Iowa v. Ragland that the Miller decision must be applied retroactively, judges must consider key factors related to child status before imposing a lengthy sentence, and life-without-parole sentences should be used rarely, if ever.
Read the rulings:
Key points of the rulings:
Gov. Terry Branstad’s mass commutation of individuals impacted by Miller to a 60-year mandatory sentence does not comply with the Supreme Court’s ban on mandatory life without parole.
“Accordingly, Ragland’s commutation did not remove the case from the mandates of Miller. The sentence served by Ragland, as commuted, still amounts to cruel and unusual punishment under the Eighth Amendment to the United States Constitution and article I, section 17 of the Iowa Constitution.” Iowa v. Ragland
The Court found that other lengthy mandatory sentences, — even if they do not use the wording “life without the possibility of parole” – are also unconstitutional under Miller. Sentences of more than 35 years cannot be mandatorily imposed upon youth without consideration of key factors.
The decision came in response to a lawsuit filed on behalf of Denem Anthony Null, who was required to serve at least 52.5 years of his seventy-five-year aggregate sentence for second-degree murder and first-degree robbery. Because he was sixteen years and ten months old at the time of his offenses, he would not be eligible for parole until age 69.
“…We believe that while a minimum of 52.5 years imprisonment is not technically a life-without-parole sentence, such a lengthy sentence imposed on a juvenile is sufficient to trigger Miller-type protections.” Iowa v. Null
The Iowa Court also reiterated the US Supreme Court’s statement in Miller that sentences of life without the possibility of parole should be imposed on kids “only in rare or uncommon cases” if at all.
Miller should be applied retroactively to people who have already been convicted and exhausted their appeals
“On balance, we think the best analysis of the issue is found in an article by Dean Erwin Chemerinsky. He stated:
‘There is a strong argument that Miller should apply retroactively: It says that it is beyond the authority of the criminal law to impose a mandatory sentence of life without parole. It would be terribly unfair to have individuals imprisoned for life without any chance of parole based on the accident of the timing of the trial.
. . . [T]he Miller Court did more than change procedures; it held that the government cannot constitutionally impose a punishment. As a substantive change in the law which puts matters outside the scope of the government’s power, the holding should apply retroactively.'” Iowa v. Ragland
In the days since the rulings, Iowa newspapers have written editorials in support of the ways that the Iowa Court has said that children must be held accountable. Read news coverage and commentary on the issue: