State v. Sweet

Summary

The Iowa Supreme Court considered whether sentencing a juvenile offender convicted of first-degree murder to life imprisonment without the possibility of parole violated article I, section 17 of the Iowa Constitution. Applying principles concerning juvenile sentencing and the Miller/Ragland factors, the court reversed the sentence and remanded for resentencing because the district court did not properly apply the constitutional standard.

Holdings

1. Article I, section 17 of the Iowa Constitution categorically prohibits sentencing juvenile offenders to life imprisonment without the possibility of parole.
2. Sweet's sentence of life imprisonment without the possibility of parole violated article I, section 17 of the Iowa Constitution and could not stand.
3. A constitutional challenge to a sentence, including a Miller-type claim, is reviewed de novo.

Questions Presented

1. Whether article I, section 17 of the Iowa Constitution categorically prohibits sentencing a juvenile offender to life imprisonment without the possibility of parole.
2. Whether the district court could constitutionally impose life without parole on Sweet based on its finding that his murders were premeditated, horrific, and demonstrated an ongoing threat to society.
3. What standard of review applies to a constitutional challenge to a juvenile life-without-parole sentence.

Disposition

reversed_and_remanded