Justia Juvenile Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court imposing a seventeen and one-half year mandatory minimum prison term before parole eligibility on Defendant's second resentencing for attempted murder during a home invasion after considering the youth sentencing factors under State v. Roby, 897 N.W.2d 127 (Iowa 2017), holding that there was no error in the sentence and that counsel was not constitutionally ineffective.Defendant was seventeen years old at the time of the crime and was since resentenced twice, once in 2014 and once in 2018, as caselaw on juvenile sentencing evolved. In this appeal from his latest resentencing, Defendant argued that the district court failed to follow the Supreme Court's 2017 mandate to apply Roby and that his counsel was constitutionally ineffective for failing to retain a defense expert on the youth sentencing factors. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in applying the Miller/Lyle/Roby factors and deciding to impose the mandatory minimum sentence; and (2) Defendant's defense counsel had no duty to present a defense expert to testify regarding the Roby factors where Defendant decided to forgo retaining a defense expert. View "State v. Majors" on Justia Law

The Supreme Court vacated the decision of the court of appeals affirming the determination of the juvenile court that termination of Father's parental rights was not in the child's best interest, holding that Iowa Code chapter 600A's best interest factors weigh in favor of terminating Father's parental rights.Mother petitioned for the termination of Father's parental rights due to abandonment under section 600A.8(3)(b). The juvenile court found that Father statutorily abandoned the child but denied Mother's petition based on its determination that termination was not in the child's best interest. The court of appeals affirmed. The Supreme Court vacated the court of appeals' decision and reversed the judgment of the district court, holding that the juvenile court erred in concluding that termination of Father's parental rights was not proper under chapter 600A. View "In re Interest of B.H.A." on Justia Law

The Supreme Court affirmed Defendant's sentence imposed in connection with his guilty plea to second-degree murder, holding that where Defendant received an individualized sentencing hearing that addressed the Miller/Lyle/Roby factors Defendant's challenge to his sentence did not constitute a proper motion to correct an illegal sentence.Defendant was sixteen years old when he fatally shot his father. After an individualized sentencing hearing the district court imposed a fifty-year prison sentence with a twenty-year mandatory minimum before parole eligibility and recited its consideration of the sentencing factors. Defendant later filed a motion to correct an illegal sentence and for appointment of counsel, alleging that the district court failed properly to apply the factors set forth in Miller v. Alabama, 567 U.S. 460 (2012), State v. Lyle, 854 N.W.2d 378 (Iowa 2014), and State v. Roby, 897 N.W.2d 127 (Iowa 2017). The district court denied the motion. The Supreme Court affirmed, holding (1) a motion claiming the district court misapplied the Miller/Lyle/Roby factors does not constitute a challenge to an illegal sentence with a concomitant statutory right to counsel; (2) Defendant's challenge to his sentence did not constitute an attack on an illegal sentence; and (3) the district court acted within its authority in sentencing Defendant to the twenty-year mandatory minimum. View "Goodwin v. Iowa District Court for Davis County" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling in favor of the Iowa Parole Board (Board) as to Petitioner's action challenging the manner in which the Board considers whether persons convicted of offenses while a juvenile should be granted parole, holding that the district court did not err.Petitioner was sixteen years old when he committed the crime of kidnapping. In his petition for judicial review brought pursuant to the Iowa Code 17A.19, Petitioner sought a declaratory judgment that a variety of substantive and procedural rights are required when a juvenile offender is considered for parole. The district court denied the Board's motion to dismiss and then proceeded to rule in favor of the Board on the merits. The Supreme Court affirmed, holding (1) dismissal was not appropriate without analyzing the merits of the underlying constitutional claims; (2) the statute and rules governing the parole process can be applied in a constitutional manner through the required Graham-Miller lens; (3) a juvenile offender has a liberty interest in the proper application of Graham-Miller principles under the Due Process Clause; and (4) Petitioner failed to establish any constitutional violations. View "Bonilla v. Iowa Board of Parole" on Justia Law

The Supreme Court declined to hold that the felony-murder rule violates due process under the Iowa or United States Constitution when it is applied to juvenile offenders pursuant to a theory of aiding and abetting.Defendant was a juvenile and unarmed when he participated in a marijuana robbery. A coparticipant, who had brought a gun to the crime, killed the robbery victim. Defendant was convicted of first-degree murder and sentenced to life imprisonment with immediate parole eligibility. The Supreme Court affirmed the conviction and sentence, holding (1) applying the felony-murder rule to juvenile offenders based on a theory of aiding and abetting is constitutional; (2) Defendant’s sentence did not constitute cruel and unusual punishment, either categorically or as applied to Defendant; (3) the trial court provided the jury with proper instructions regarding the types of assault required to establish the forcible felony robbery element of felony murder; and (4) the record was inadequate for the Court to address some of Defendant’s claims of ineffective assistance of counsel, and the remainder of Defendant’s ineffective assistance of counsel claims were without merit. View "State v. Harrison" on Justia Law

The Supreme Court affirmed the decision of the court of appeals finding substantial evidence that the juvenile in this case committed a sex offense by force and that the sex offender registry requirements imposed upon the juvenile by law did not violate the prohibition against cruel and unusual punishment under either the state or federal Constitutions.The juvenile court found the juvenile committed a sex offense by force and required him to register as a sex offender under Iowa Code 692A.103(4), the mandatory sex offender registry statute. The court of appeals affirmed. The Supreme Court affirmed, holding that automatic, mandatory registration for certain juvenile sex offenders is punishment but that such registration does not amount to cruel and unusual punishment. View "In re T.H." on Justia Law

Iowa Code 902.1(2)(a)(1), which gives the district court the option to sentence a juvenile offender convicted of murder in the first degree to life imprisonment without the possibility of parole, is unconstitutional based on the Supreme Court’s holding in State v. Sweet, 879 N.W.2d 811 (Iowa 2016), which held that such a sentence for all juvenile offenders violates article I, section 17 of the Iowa Constitution. However, the unconstitutional portion of the statute does not render the remainder of section 902.1(2)(a) unconstitutional.Defendant was convicted of first-degree murder as a juvenile offender. Defendant challenged his sentence of life imprisonment with the possibility of parole after serving a minimum term of twenty-five years confinement. Defendant filed a motion to correct an illegal sentence, arguing that the sentencing scheme for juvenile offenders convicted of first-degree murder set forth in section 902.1(2) was cruel and unusual punishment under the Iowa Constitution. The Supreme Court held (1) section 902.1(2)(a)(1) is unconstitutional, but the remainder of section 902.1(2) is constitutional; and (2) Defendant’s case must be remanded for resentencing under State v. Roby, 897 N.W.2d 127 (Iowa 2017), which was decided subsequent to Defendant’s resentencing. View "State v. Zarate" on Justia Law

A hearing conducted by the district court to determine if a juvenile offender should be sentenced to a minimum term of incarceration without eligibility for parole did not, in this case, comply with constitutional safeguards.The district court concluded that the juvenile in this case should serve the statutory mandatory minimum term of incarceration before becoming eligible for parole. The court of appeals affirmed. The Supreme Court reversed, holding that the district court abused its discretion in its application of the sentencing factors because critical conclusions drawn by the court at the sentencing hearing were not grounded in science but rather based on generalized attitudes of criminal behavior that may or may not be correct as applied to juveniles. The court remanded the case for resentencing in light of State v. Roby, 897 N.W.2d, 127 (Iowa 2017). View "State v. White" on Justia Law

Iowa Const. art. I, section 17 does not categorically prohibit a district court form sentencing a juvenile offender to a minimum term of incarceration without the possibility of parole, provided that the court only imposes the sentence after a complete and careful consideration of the relevant mitigating factors of youth.Defendant, who was a juvenile at the time of his offense, was resentenced to a minimum term of incarceration of seventeen and one-half years for sexual abuse in the second degree. Defendant appealed, arguing that any minimum term of incarceration without the possibility of parole is unconstitutional. The court of appeals affirmed the sentence. The Supreme Court remanded for resentencing, holding that, while the Iowa Constitution does not require abandonment of the practice at issue, the district court abused its discretion in this case by imposing a sentence of incarceration without parole eligibility. View "State v. Roby" on Justia Law

Defendant, a juvenile, pleaded guilty to four counts of willful injury causing serious injury. Pursuant to the plea agreement, the district court sentenced Defendant to indeterminate sentences not to exceed ten years on each of the four counts to run consecutively for a maximum sentence of forty years. No mandatory minimum sentence was imposed, but because Defendant’s crime was a forcible felony, the sentencing judge was unable to consider a deferred judgment or probation as a sentencing option. Defendant filed a motion to correct an illegal sentence, which the district court denied. The Supreme Court affirmed the judgment of the district court, holding (1) the forcible felony sentencing statute, Iowa Code 907.3, is not unconstitutional as applied to juvenile offenders; and (2) in considering a motion to correct an illegal sentence, the district court is not required to conduct an individualized sentencing hearing as to all juveniles regardless of whether the sentence has a mandatory term of years. View "State v. Propps" on Justia Law