Bonilla v. State

Summary

The Iowa Supreme Court held that sentencing a juvenile offender to life imprisonment without parole for a nonhomicide offense violated the Eighth Amendment under Graham v. Florida. It severed the parole-prohibiting provisions of Iowa Code sections 902.1 and 906.5 as applied to Bonilla, leaving a life sentence with the possibility of parole. The court vacated the sentence and remanded for resentencing.

Holdings

1. The mandatory sentence of life imprisonment without the possibility of parole imposed on Bonilla for a nonhomicide offense committed when he was a juvenile violated the Eighth Amendment.
2. A claim that a sentence is unconstitutional as cruel and unusual punishment is a challenge to an illegal sentence and may be raised at any time; Bonilla's postconviction application was therefore construed as a motion to correct an illegal sentence.
3. The parole restrictions in Iowa Code sections 902.1 and 906.5 were unconstitutional as applied to Bonilla and could be severed from the statutes, leaving a life sentence with the possibility of parole and annual parole review.

Questions Presented

1. Whether the Eighth Amendment prohibits sentencing a juvenile nonhomicide offender to life imprisonment without parole.
2. Whether Bonilla's postconviction claim could be treated as a challenge to an illegal sentence and raised on appeal.
3. Whether the unconstitutional parole restrictions in Iowa Code sections 902.1 and 906.5 could be severed so that Bonilla would remain sentenced to life imprisonment but become eligible for parole consideration.

Disposition

reversed_and_remanded