Eighth Amendment analysis (Iowa) · Go Syfert
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Eighth Amendment analysis in Iowa

28 Iowa opinions name it 2 courts 1999–2022 2 in the last five years

The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (27)

CaseFollowedCited
Graham v. Floridagreen
scotus · 2010 · cited in 11 Iowa opinions naming this issue, 2012–2017
2 sentences

2016After Bruegger, federal case law clarified the “lexicon for Eighth Amendment analysis no longer includes the terms ‘facial challenge’ and ‘as- applied challenge.’ Instead, the defendant must challenge his sentence under the ‘categorical’ approach or make a ‘gross proportionality challenge to [the] 10 particular defendant’s sentence.’” State v. Oliver, 812 N.W.2d 636, 639-40 (Iowa 2012) (citing Graham v. Florida, 560 U.S. 48, 60 (2010)).

2015He also contends the sentence he received is grossly disproportionate because fifty years is overly harsh for a first-time, nonviolent offense.7 7 Following the United States Supreme Court ruling in Graham v. Florida, 560 U.S. 48 , 61 (2011), “[T]he federal lexicon for Eighth Amendment analysis no longer includes the terms ‘facial challenge’ and ‘as-applied challenge.’” State v. Oliver, 812 N.W.2d 636 , 639–40 (Iowa 2012).

611
Estelle v. Gamblegreen
scotus · 1976 · cited in 4 Iowa opinions naming this issue, 2013–2017
2 sentences

2017Proportionality is key in an Eighth Amendment analysis, and we view proportionality according to “the evolving standards of decency that mark the progress of a maturing society.” Id. (quoting Estelle v. Gamble, 429 U.S. 97, 102 , 97 S. Ct. 285, 290 (1976)). 10 In 2005, the Supreme Court held in Roper that the sentence of capital punishment when imposed upon a juvenile violates the prohibition on cruel and unusual punishment contained in the Eighth Amendment. 543 U.S. at 560 , 126 S. Ct. 1190 .

2017Proportionality is key in an Eighth Amendment analysis, and we view proportionality according to “the evolving standards of decency that mark the progress of a maturing society.” Id. (quoting Estelle v. Gamble, 429 U.S. 97, 102 , 97 S. Ct. 285, 290 (1976)). 10 In 2005, the Supreme Court held in Roper that the sentence of capital punishment when imposed upon a juvenile violates the prohibition on cruel and unusual punishment contained in the Eighth Amendment. 543 U.S. at 560 , 126 S. Ct. 1190 .

44
State of Iowa v. Charles James David Olivergreen
iowa · 2012 · cited in 5 Iowa opinions naming this issue, 2014–2020
2 sentences

2020“The federal lexicon for Eighth Amendment analysis no longer includes the terms ‘facial challenge’ and ‘as-applied challenge.’” State v. Oliver, 812 N.W.2d 636 , 639–40 (Iowa 2012).

2016After Bruegger, federal case law clarified the “lexicon for Eighth Amendment analysis no longer includes the terms ‘facial challenge’ and ‘as- applied challenge.’ Instead, the defendant must challenge his sentence under the ‘categorical’ approach or make a ‘gross proportionality challenge to [the] 10 particular defendant’s sentence.’” State v. Oliver, 812 N.W.2d 636, 639-40 (Iowa 2012) (citing Graham v. Florida, 560 U.S. 48, 60 (2010)).

35
Gregg v. Georgiagreen
scotus · 1976 · cited in 2 Iowa opinions naming this issue, 2013–2018
2 sentences

2018The United States Supreme Court has observed that "the 'clearest and most reliable objective evidence of contemporary values is the legislation enacted by the country's legislatures.' " Atkins v. Virginia , 536 U.S. 304 , 312, 122 S.Ct. 2242 , 2247, 153 L.Ed.2d 335 (2002) (quoting Penry v. Lynaugh , 492 U.S. 302 , 331, 109 S.Ct. 2934 , 2953, 106 L.Ed.2d 256 (1989), abrogated on other grounds by Atkins , 536 U.S. at 321 , 122 S.Ct. at 2252 ); see also Gregg v. Georgia , 428 U.S. 153 , 174-76, 96 S.Ct. 2909 , 2925-26, 49 L.Ed.2d 859 (1976) (basing Eighth Amendment analysis on state legislative j

2018The United States Supreme Court has observed that "the 'clearest and most reliable objective evidence of contemporary values is the legislation enacted by the country's legislatures.' " Atkins v. Virginia , 536 U.S. 304 , 312, 122 S.Ct. 2242 , 2247, 153 L.Ed.2d 335 (2002) (quoting Penry v. Lynaugh , 492 U.S. 302 , 331, 109 S.Ct. 2934 , 2953, 106 L.Ed.2d 256 (1989), abrogated on other grounds by Atkins , 536 U.S. at 321 , 122 S.Ct. at 2252 ); see also Gregg v. Georgia , 428 U.S. 153 , 174-76, 96 S.Ct. 2909 , 2925-26, 49 L.Ed.2d 859 (1976) (basing Eighth Amendment analysis on state legislative j

22
Andrew Conley v. State of Indianagreen
ind · 2012 · cited in 2 Iowa opinions naming this issue, 2015–2015
2 sentences

2015App. Ct. 2015) (“Under Miller, a juvenile defendant can be sentenced to natural life in prison without parole, so long as the natural life sentence is at the trial court’s discretion and not mandatory.”); Conley v. State, 972 N.E.2d 864, 879 (Ind. 2012) (“Our holding that [Indiana’s discretionary] life- without-parole sentence is not unconstitutional is not altered by Miller.”); State v. Fletcher, 149 So. 3d 934, 941 (La.

2015Instead, defendant’s sentence of life without parole violates the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment is just and appropriate in light of defendant's age, maturity, and the other factors discussed in Miller.”); Washington v. State, 103 So.3d 917, 920 (Fla.Dist.Ct.App.2012) ("Under Miller , a sentence of life without the possibility of parole remains a constitutionally permissible sentencing option.”); Foster v. State, 294 Ga. 383 , 754 S.E.2d 33, 37 (2014) (finding no Eighth Amendment violation in a discre

22
State v. Fletchergreen
lactapp · 2014 · cited in 2 Iowa opinions naming this issue, 2015–2015
2 sentences

2015App. Ct. 2015) (“Under Miller, a juvenile defendant can be sentenced to natural life in prison without parole, so long as the natural life sentence is at the trial court’s discretion and not mandatory.”); Conley v. State, 972 N.E.2d 864, 879 (Ind. 2012) (“Our holding that [Indiana’s discretionary] life- without-parole sentence is not unconstitutional is not altered by Miller.”); State v. Fletcher, 149 So. 3d 934, 941 (La.

2015Instead, defendant’s sentence of life without parole violates the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment is just and appropriate in light of defendant's age, maturity, and the other factors discussed in Miller.”); Washington v. State, 103 So.3d 917, 920 (Fla.Dist.Ct.App.2012) ("Under Miller , a sentence of life without the possibility of parole remains a constitutionally permissible sentencing option.”); Foster v. State, 294 Ga. 383 , 754 S.E.2d 33, 37 (2014) (finding no Eighth Amendment violation in a discre

22
Foster v. Stategreen
ga · 2014 · cited in 2 Iowa opinions naming this issue, 2015–2015
2 sentences

2015Instead, defendant’s sentence of life without parole violates the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment is just and appropriate in light of defendant's age, maturity, and the other factors discussed in Miller.”); Washington v. State, 103 So.3d 917, 920 (Fla.Dist.Ct.App.2012) ("Under Miller , a sentence of life without the possibility of parole remains a constitutionally permissible sentencing option.”); Foster v. State, 294 Ga. 383 , 754 S.E.2d 33, 37 (2014) (finding no Eighth Amendment violation in a discre

2015Instead, defendant’s sentence of life without parole violates the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment is just and appropriate in light of defendant's age, maturity, and the other factors discussed in Miller.”); Washington v. State, 103 So.3d 917, 920 (Fla.Dist.Ct.App.2012) ("Under Miller , a sentence of life without the possibility of parole remains a constitutionally permissible sentencing option.”); Foster v. State, 294 Ga. 383 , 754 S.E.2d 33, 37 (2014) (finding no Eighth Amendment violation in a discre

22
Tanner Advertising Group, L.L.C. v. Fayette Countygreen
ca11 · 2005 · cited in 2 Iowa opinions naming this issue, 2009–2009
2 sentences

2009See, e.g., Wis. Stat. § 939.615 (2009) (providing that a sex offender may be sentenced to lifetime supervision); see also United States v. Moriarty, 429 F.3d 1012, 1025 (11th Cir.2005) (“[W]e conclude that a lifetime term of supervised release is not grossly disproportionate to his child pornography offenses under 18 U.S.C. § 2552A, and his Eighth Amendment claim therefore fails.”).

2009See, e.g., Wis. Stat. § 939.615 (2009) (providing that a sex offender may be sentenced to lifetime supervision); see also United States v. Moriarty, 429 F.3d 1012, 1025 (11th Cir.2005) (“[W]e conclude that that a lifetime term of supervised release is not grossly disproportionate to his child pornography offenses under 18 U.S.C. § 2552A, and his Eighth Amendment claim therefore fails.”).

22
Roper v. Simmonsgreen
scotus · 2005 · cited in 5 Iowa opinions naming this issue, 2013–2018
2 sentences

2017Proportionality is key in an Eighth Amendment analysis, and we view proportionality according to “the evolving standards of decency that mark the progress of a maturing society.” Id. (quoting Estelle v. Gamble, 429 U.S. 97, 102 , 97 S. Ct. 285, 290 (1976)). 10 In 2005, the Supreme Court held in Roper that the sentence of capital punishment when imposed upon a juvenile violates the prohibition on cruel and unusual punishment contained in the Eighth Amendment. 543 U.S. at 560 , 126 S. Ct. 1190 .

2017Proportionality is key in an Eighth Amendment analysis, and we view proportionality according to “the evolving standards of decency that mark the progress of a maturing society.” Id. (quoting Estelle v. Gamble, 429 U.S. 97, 102 , 97 S. Ct. 285, 290 (1976)). 10 In 2005, the Supreme Court held in Roper that the sentence of capital punishment when imposed upon a juvenile violates the prohibition on cruel and unusual punishment contained in the Eighth Amendment. 543 U.S. at 560 , 126 S. Ct. 1190 .

15
Miller v. Alabamagreen
scotus · 2012 · cited in 2 Iowa opinions naming this issue, 2013–2019
2 sentences

2019Id. (citation omitted) (footnote omitted); see also People v. Tate, 352 P.3d 959, 970 (Colo. 2015) (holding Miller does not prohibit a mandatory minimum sentence of life with possibility of parole after forty years); State v. Taylor G., 110 A.3d 338 , 347 (Conn. 2015) (“The limitations that mandatory minimum sentences place on a trial court’s discretion, however, do not automatically constitute an eighth amendment violation.”); State v. Michel, 257 So. 3d 3, 4, 8 (Fla. 2018) (holding that a statute requiring a twenty-five-year mandatory minimum sentence for first-degree murder does not violate

2013In determining whether a criminal penalty amounts to an Eighth Amendment violation, the Supreme Court looks to contemporary norms, or, in the court’s phraseology, from “the evolving standards of decency that mark the progress of a maturing society.” Trop v. Dulles, 356 U.S. 86, 101 , 78 S.Ct. 590, 598 , 2 L.Ed.2d 630, 642 (1958) (plurality opinion); accord Miller, 567 U.S. at - , 132 S.Ct. at 2463 , 183 L.Ed.2d at 417 ; Graham , 560 U.S. at -, 130 S.Ct. at 2021 , 176 L.Ed.2d at 835 ; Kennedy v. Louisiana, 554 U.S. 407, 419 , 128 S.Ct. 2641, 2649 , 171 L.Ed.2d 525, 538 , opinion modified on den

12
State v. Dullgreen
kan · 2015 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017Id. at 647-48.

2017Id. at 647-48.

12
In re Disciplinary Action Against Watersgreen
minn · 2014 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019Id. (citation omitted) (footnote omitted); see also People v. Tate, 352 P.3d 959, 970 (Colo. 2015) (holding Miller does not prohibit a mandatory minimum sentence of life with possibility of parole after forty years); State v. Taylor G., 110 A.3d 338 , 347 (Conn. 2015) (“The limitations that mandatory minimum sentences place on a trial court’s discretion, however, do not automatically constitute an eighth amendment violation.”); State v. Michel, 257 So. 3d 3, 4, 8 (Fla. 2018) (holding that a statute requiring a twenty-five-year mandatory minimum sentence for first-degree murder does not violate

11
State v. Linkgreen
orctapp · 2019 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019Id. (citation omitted) (footnote omitted); see also People v. Tate, 352 P.3d 959, 970 (Colo. 2015) (holding Miller does not prohibit a mandatory minimum sentence of life with possibility of parole after forty years); State v. Taylor G., 110 A.3d 338 , 347 (Conn. 2015) (“The limitations that mandatory minimum sentences place on a trial court’s discretion, however, do not automatically constitute an eighth amendment violation.”); State v. Michel, 257 So. 3d 3, 4, 8 (Fla. 2018) (holding that a statute requiring a twenty-five-year mandatory minimum sentence for first-degree murder does not violate

11
State of Florida v. Budry Michelgreen
fla · 2018 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019Id. (citation omitted) (footnote omitted); see also People v. Tate, 352 P.3d 959, 970 (Colo. 2015) (holding Miller does not prohibit a mandatory minimum sentence of life with possibility of parole after forty years); State v. Taylor G., 110 A.3d 338 , 347 (Conn. 2015) (“The limitations that mandatory minimum sentences place on a trial court’s discretion, however, do not automatically constitute an eighth amendment violation.”); State v. Michel, 257 So. 3d 3, 4, 8 (Fla. 2018) (holding that a statute requiring a twenty-five-year mandatory minimum sentence for first-degree murder does not violate

11
State v. Keaira Browngreen
kan · 2014 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019Id. (citation omitted) (footnote omitted); see also People v. Tate, 352 P.3d 959, 970 (Colo. 2015) (holding Miller does not prohibit a mandatory minimum sentence of life with possibility of parole after forty years); State v. Taylor G., 110 A.3d 338 , 347 (Conn. 2015) (“The limitations that mandatory minimum sentences place on a trial court’s discretion, however, do not automatically constitute an eighth amendment violation.”); State v. Michel, 257 So. 3d 3, 4, 8 (Fla. 2018) (holding that a statute requiring a twenty-five-year mandatory minimum sentence for first-degree murder does not violate

11
People v. Tate Banks v. People Jensen v. Peoplegreen
colo · 2015 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019Id. (citation omitted) (footnote omitted); see also People v. Tate, 352 P.3d 959, 970 (Colo. 2015) (holding Miller does not prohibit a mandatory minimum sentence of life with possibility of parole after forty years); State v. Taylor G., 110 A.3d 338 , 347 (Conn. 2015) (“The limitations that mandatory minimum sentences place on a trial court’s discretion, however, do not automatically constitute an eighth amendment violation.”); State v. Michel, 257 So. 3d 3, 4, 8 (Fla. 2018) (holding that a statute requiring a twenty-five-year mandatory minimum sentence for first-degree murder does not violate

11
Washington v. Stategreen
fladistctapp · 2012 · cited in 1 Iowa opinions naming this issue, 2015–2015
1 sentence

2015Instead, defendant’s sentence of life without parole violates the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment is just and appropriate in light of defendant's age, maturity, and the other factors discussed in Miller.”); Washington v. State, 103 So.3d 917, 920 (Fla.Dist.Ct.App.2012) ("Under Miller , a sentence of life without the possibility of parole remains a constitutionally permissible sentencing option.”); Foster v. State, 294 Ga. 383 , 754 S.E.2d 33, 37 (2014) (finding no Eighth Amendment violation in a discre

11
State of Iowa v. Anthony Allen Hoeckgreen
iowa · 2014 · cited in 1 Iowa opinions naming this issue, 2015–2015
1 sentence

2015Considering only the Eighth Amendment issue raised on appeal, the court held: “For a juvenile previously sentenced to life in prison without parole for a nonhomicide crime, the appropriate remedy under Graham was to sever the 12 parole ineligibility from the juvenile’s sentence and sentence the juvenile to life in prison with the possibility of parole.” State v. Hoeck, 843 N.W.2d 67, 71 (Iowa 2014) (endorsing procedure followed in Bonilla, 791 N.W.2d at 701 ).

11
Ewing v. Californiagreen
scotus · 2003 · cited in 1 Iowa opinions naming this issue, 2013–2013
2 sentences

2013Although some justices have disagreed with this interpretation, see Ewing, 538 U.S. at 31-32 , 123 S.Ct. at 1190-91 , 155 L.Ed.2d at 124 (Scalia, J., concurring), the Supreme Court has thus repeatedly rejected a narrow originalist or historical approach to the Eighth Amendment.

2013Although some justices have disagreed with this interpretation, see Ewing, 538 U.S. at 31-32 , 123 S.Ct. at 1190-91 , 155 L.Ed.2d at 124 (Scalia, J., concurring), the Supreme Court has thus repeatedly rejected a narrow originalist or historical approach to the Eighth Amendment.

11
Lockyer v. Andradegreen
scotus · 2003 · cited in 1 Iowa opinions naming this issue, 2013–2013
11
Stanford v. Kentuckyred
scotus · 1989 · cited in 1 Iowa opinions naming this issue, 2013–2013
2 sentences

2013In determining whether a criminal penalty amounts to an Eighth Amendment violation, the Supreme Court looks to contemporary norms, or, in the court’s phraseology, from “the evolving standards of decency that mark the progress of a maturing society.” Trop v. Dulles, 356 U.S. 86, 101 , 78 S.Ct. 590, 598 , 2 L.Ed.2d 630, 642 (1958) (plurality opinion); accord Miller, 567 U.S. at - , 132 S.Ct. at 2463 , 183 L.Ed.2d at 417 ; Graham , 560 U.S. at -, 130 S.Ct. at 2021 , 176 L.Ed.2d at 835 ; Kennedy v. Louisiana, 554 U.S. 407, 419 , 128 S.Ct. 2641, 2649 , 171 L.Ed.2d 525, 538 , opinion modified on den

2013In determining whether a criminal penalty amounts to an Eighth Amendment violation, the Supreme Court looks to contemporary norms, or, in the court’s phraseology, from “the evolving standards of decency that mark the progress of a maturing society.” Trop v. Dulles, 356 U.S. 86, 101 , 78 S.Ct. 590, 598 , 2 L.Ed.2d 630, 642 (1958) (plurality opinion); accord Miller, 567 U.S. at - , 132 S.Ct. at 2463 , 183 L.Ed.2d at 417 ; Graham , 560 U.S. at -, 130 S.Ct. at 2021 , 176 L.Ed.2d at 835 ; Kennedy v. Louisiana, 554 U.S. 407, 419 , 128 S.Ct. 2641, 2649 , 171 L.Ed.2d 525, 538 , opinion modified on den

11
Trop v. Dullesgreen
scotus · 1958 · cited in 1 Iowa opinions naming this issue, 2013–2013
11
Furman v. Georgiagreen
scotus · 1972 · cited in 1 Iowa opinions naming this issue, 2013–2013
11
State v. Brueggergreen
iowa · 2009 · cited in 1 Iowa opinions naming this issue, 2012–2012
11
Whitmore Ex Rel. Simmons v. Arkansasgreen
scotus · 1990 · cited in 1 Iowa opinions naming this issue, 2008–2008
11
Harmelin v. Michigangreen
scotus · 1991 · cited in 1 Iowa opinions naming this issue, 1999–1999
11
State v. Augustgreen
iowa · 1999 · cited in 1 Iowa opinions naming this issue, 1999–1999
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
Rutherford v. Crosby green
scotus · 2006
2 sentences

2017Proportionality is key in an Eighth Amendment analysis, and we view proportionality according to “the evolving standards of decency that mark the progress of a maturing society.” Id. (quoting Estelle v. Gamble, 429 U.S. 97, 102 , 97 S. Ct. 285, 290 (1976)). 10 In 2005, the Supreme Court held in Roper that the sentence of capital punishment when imposed upon a juvenile violates the prohibition on cruel and unusual punishment contained in the Eighth Amendment. 543 U.S. at 560 , 126 S. Ct. 1190 .

2017Proportionality is key in an Eighth Amendment analysis, and we view proportionality according to “the evolving standards of decency that mark the progress of a maturing society.” Id. (quoting Estelle v. Gamble, 429 U.S. 97, 102 , 97 S. Ct. 285, 290 (1976)). 10 In 2005, the Supreme Court held in Roper that the sentence of capital punishment when imposed upon a juvenile violates the prohibition on cruel and unusual punishment contained in the Eighth Amendment. 543 U.S. at 560 , 126 S. Ct. 1190 .

32017–2017
State v. Jones green
iowa · 1980
2 sentences

2022Id.

1999Id.

21999–2022
Whitley v. Albers green
scotus · 1986
1 sentence

2022“The general requirement that an Eighth Amendment claimant allege and prove the unnecessary and wanton infliction of pain should also be applied with due regard for differences in the kind of conduct against which an Eighth Amendment objection is lodged.” Id. at 320 .

12022–2022
Penry v. Lynaugh red
scotus · 1989
2 sentences

2018The United States Supreme Court has observed that "the 'clearest and most reliable objective evidence of contemporary values is the legislation enacted by the country's legislatures.' " Atkins v. Virginia , 536 U.S. 304 , 312, 122 S.Ct. 2242 , 2247, 153 L.Ed.2d 335 (2002) (quoting Penry v. Lynaugh , 492 U.S. 302 , 331, 109 S.Ct. 2934 , 2953, 106 L.Ed.2d 256 (1989), abrogated on other grounds by Atkins , 536 U.S. at 321 , 122 S.Ct. at 2252 ); see also Gregg v. Georgia , 428 U.S. 153 , 174-76, 96 S.Ct. 2909 , 2925-26, 49 L.Ed.2d 859 (1976) (basing Eighth Amendment analysis on state legislative j

2018The United States Supreme Court has observed that "the 'clearest and most reliable objective evidence of contemporary values is the legislation enacted by the country's legislatures.' " Atkins v. Virginia , 536 U.S. 304 , 312, 122 S.Ct. 2242 , 2247, 153 L.Ed.2d 335 (2002) (quoting Penry v. Lynaugh , 492 U.S. 302 , 331, 109 S.Ct. 2934 , 2953, 106 L.Ed.2d 256 (1989), abrogated on other grounds by Atkins , 536 U.S. at 321 , 122 S.Ct. at 2252 ); see also Gregg v. Georgia , 428 U.S. 153 , 174-76, 96 S.Ct. 2909 , 2925-26, 49 L.Ed.2d 859 (1976) (basing Eighth Amendment analysis on state legislative j

12018–2018
Atkins v. Virginia green
scotus · 2002
2 sentences

2018The United States Supreme Court has observed that "the 'clearest and most reliable objective evidence of contemporary values is the legislation enacted by the country's legislatures.' " Atkins v. Virginia , 536 U.S. 304 , 312, 122 S.Ct. 2242 , 2247, 153 L.Ed.2d 335 (2002) (quoting Penry v. Lynaugh , 492 U.S. 302 , 331, 109 S.Ct. 2934 , 2953, 106 L.Ed.2d 256 (1989), abrogated on other grounds by Atkins , 536 U.S. at 321 , 122 S.Ct. at 2252 ); see also Gregg v. Georgia , 428 U.S. 153 , 174-76, 96 S.Ct. 2909 , 2925-26, 49 L.Ed.2d 859 (1976) (basing Eighth Amendment analysis on state legislative j

2018The United States Supreme Court has observed that "the 'clearest and most reliable objective evidence of contemporary values is the legislation enacted by the country's legislatures.' " Atkins v. Virginia , 536 U.S. 304 , 312, 122 S.Ct. 2242 , 2247, 153 L.Ed.2d 335 (2002) (quoting Penry v. Lynaugh , 492 U.S. 302 , 331, 109 S.Ct. 2934 , 2953, 106 L.Ed.2d 256 (1989), abrogated on other grounds by Atkins , 536 U.S. at 321 , 122 S.Ct. at 2252 ); see also Gregg v. Georgia , 428 U.S. 153 , 174-76, 96 S.Ct. 2909 , 2925-26, 49 L.Ed.2d 859 (1976) (basing Eighth Amendment analysis on state legislative j

12018–2018
Rummel v. Estelle green
scotus · 1980
2 sentences

2018As noted by one observer, the United States Supreme Court in Rummel v. Estelle , 445 U.S. 263 , 280, 100 S.Ct. 1133 , 1142, 63 L.Ed.2d 382 (1980), cited the prisoner's eligibility for parole after twelve years as a factor in upholding a sentence from Eighth Amendment challenge.

2018As noted by one observer, the United States Supreme Court in Rummel v. Estelle , 445 U.S. 263 , 280, 100 S.Ct. 1133 , 1142, 63 L.Ed.2d 382 (1980), cited the prisoner's eligibility for parole after twelve years as a factor in upholding a sentence from Eighth Amendment challenge.

12018–2018
Moore v. Texas green
scotus · 2017
2 sentences

2018Moore v. Texas , 581 U.S. ----, ----, 137 S.Ct. 1039 , 1056-57, 197 L.Ed.2d 416 (2017) (Roberts, C.J., dissenting) (first quoting Atkins , 536 U.S. at 312 , 122 S.Ct. at 2247 ; then quoting Gregg , 428 U.S. at 175 , 96 S.Ct. at 2926 ; then quoting id. at 176 , 96 S.Ct. at 2926 ; then quoting Roper , 543 U.S. at 564 , 125 S.Ct. at 1192 ).

2018Moore v. Texas , 581 U.S. ----, ----, 137 S.Ct. 1039 , 1056-57, 197 L.Ed.2d 416 (2017) (Roberts, C.J., dissenting) (first quoting Atkins , 536 U.S. at 312 , 122 S.Ct. at 2247 ; then quoting Gregg , 428 U.S. at 175 , 96 S.Ct. at 2926 ; then quoting id. at 176 , 96 S.Ct. at 2926 ; then quoting Roper , 543 U.S. at 564 , 125 S.Ct. at 1192 ).

12018–2018
Julio Bonilla Vs. State Of Iowa green
iowa · 2010
1 sentence

2015Considering only the Eighth Amendment issue raised on appeal, the court held: “For a juvenile previously sentenced to life in prison without parole for a nonhomicide crime, the appropriate remedy under Graham was to sever the 12 parole ineligibility from the juvenile’s sentence and sentence the juvenile to life in prison with the possibility of parole.” State v. Hoeck, 843 N.W.2d 67, 71 (Iowa 2014) (endorsing procedure followed in Bonilla, 791 N.W.2d at 701 ).

12015–2015
People of Michigan v. Raymond Curtis Carp green
mich · 2014
1 sentence

2015It merely required that a sentencing court consider mitigating facts related to the juvenile's youth before imposing a sentence without benefit of parole.”); People v. Carp, 496 Mich. 440 , 852 N.W.2d 801 , 841 (2014), petitions for cert. filed sub nom.

12015–2015
Kennedy v. Louisiana green
scotus · 2008
12013–2013
Snipes v. Horton green
sc · 1924
2 sentences

2013In determining whether a criminal penalty amounts to an Eighth Amendment violation, the Supreme Court looks to contemporary norms, or, in the court’s phraseology, from “the evolving standards of decency that mark the progress of a maturing society.” Trop v. Dulles, 356 U.S. 86, 101 , 78 S.Ct. 590, 598 , 2 L.Ed.2d 630, 642 (1958) (plurality opinion); accord Miller, 567 U.S. at - , 132 S.Ct. at 2463 , 183 L.Ed.2d at 417 ; Graham , 560 U.S. at -, 130 S.Ct. at 2021 , 176 L.Ed.2d at 835 ; Kennedy v. Louisiana, 554 U.S. 407, 419 , 128 S.Ct. 2641, 2649 , 171 L.Ed.2d 525, 538 , opinion modified on den

2013In determining whether a criminal penalty amounts to an Eighth Amendment violation, the Supreme Court looks to contemporary norms, or, in the court’s phraseology, from “the evolving standards of decency that mark the progress of a maturing society.” Trop v. Dulles, 356 U.S. 86, 101 , 78 S.Ct. 590, 598 , 2 L.Ed.2d 630, 642 (1958) (plurality opinion); accord Miller, 567 U.S. at - , 132 S.Ct. at 2463 , 183 L.Ed.2d at 417 ; Graham , 560 U.S. at -, 130 S.Ct. at 2021 , 176 L.Ed.2d at 835 ; Kennedy v. Louisiana, 554 U.S. 407, 419 , 128 S.Ct. 2641, 2649 , 171 L.Ed.2d 525, 538 , opinion modified on den

12013–2013
Schlesinger v. Reservists Committee to Stop the War green
scotus · 1974
12008–2008

Statutes the citing opinions construe

IA § Iowa Code § 901.5 (13) IA § Iowa Code § 902.12 (9) IA § Iowa Code § 232.8 (7) IA § Iowa Code § 902.9 (7) IA § Iowa Code § 902.1 (6) IA § Iowa Code § 903B.1 (6) IA § Iowa Code § 907.3 (6) IA § Iowa Code § 232.45 (5) IA § Iowa Code § 711.1 (5) IA § Iowa Code § 814.6 (5) IA § Iowa Code § 708.4 (4) IA § Iowa Code § 709.1 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 305 (1983–2026) TX 222 (1988–2026) IL 124 (1981–2026) FL 85 (1981–2026) PA 80 (1985–2026) VA 62 (1983–2026) OH 48 (1999–2025) KS 43 (2001–2026) MS 42 (1986–2025) WA 37 (1983–2023) OR 35 (1992–2025) AZ 33 (1978–2024) TN 30 (1994–2022) MA 30 (1976–2026) CO 29 (1990–2026) MI 28 (1984–2025) IA 28 (1999–2022) ID 27 (1983–2024) SD 24 (1980–2024) AL 24 (1984–2026) NY 23 (1974–2026) OK 22 (1987–2020) MO 21 (1993–2023) IN 20 (1979–2024) NC 20 (1991–2025) NJ 20 (1983–2022) GA 18 (1992–2026) KY 17 (2003–2024) MD 17 (1972–2026) CT 17 (1995–2022) WI 14 (1994–2026) AR 14 (1996–2026) LA 13 (1987–2025) DE 13 (1988–2022) DC 13 (1975–2019) UT 13 (1995–2025) SC 12 (1991–2025) WY 12 (1986–2023) NE 11 (1999–2024) NM 9 (1991–2019) MN 8 (1976–2024) MT 8 (1996–2022) WV 7 (1994–2023) VT 6 (1998–2018) NV 6 (1979–2020) ND 6 (1992–2022) ME 5 (1987–2015) AK 4 (2010–2022) VI 3 (2003–2012) NH 3 (1980–2013) RI 3 (2004–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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