cruel and unusual punishment clause in Iowa

2022Of particular relevance here is State v. Lyle, in which this court held that “all mandatory minimum sentences of imprisonment for youthful offenders are unconstitutional under the cruel and unusual punishment clause in article I, section 17 of our constitution.” 854 N.W.2d at 400 .

2021Our supreme court held in Lyle that “all mandatory minimum sentences of imprisonment for youthful offenders are unconstitutional under the cruel and unusual punishment clause in article I, section 17 of our constitution.” 854 N.W.2d at 400 .

2015See Iowa Code § 903B.1. 4 principles as outlined by the United States Supreme Court for addressing a cruel- and-unusual-punishment challenge.” Bruegger, 773 N.W.2d at 883 .

2015Adcock has not alleged any distinction between the functions of the state and federal constitutions, and we therefore “apply the general principles as outlined by the United States Supreme Court for addressing a cruel-and-unusual- punishment challenge . . . .” Bruegger, 773 N.W.2d at 883 .

2017In State v. Null, we considered the cruel and unusual punishment clause of the Iowa Constitution. 836 N.W.2d 41, 70 (Iowa 2013); see also Iowa Const. art.

2017In State v. Null, we considered the cruel and unusual punishment clause of the Iowa Constitution. 836 N.W.2d 41, 70 (Iowa 2013); see also Iowa Const. art.

2009See In re Detention of Garren, 620 N.W.2d 275 , 280 n. 1 (Iowa 2000).

2009See In re Detention of Garren, 620 N.W.2d 275 , 280 n. 1 (Iowa 2000) (refusing to deviate from federal analysis in considering state constitutional claim because appellant “suggested no legal deficiency in the federal principles”).

2019We held in State v. Sweet that juvenile offenders cannot be sentenced to life without the possibility of parole under the cruel and unusual punishment clause of the Iowa Constitution. 879 N.W.2d 811, 839 (Iowa 2016).

2018See Sweet , 879 N.W.2d at 840 ("[T]he new statutory scheme adopted by our legislature for sentencing juvenile offenders convicted of first-degree murder to life without the possibility of parole violates the cruel and unusual punishment clause.").

2019State v. Oliver, 812 N.W.2d 636 , 639–41 (Iowa 2012).

2017See Oliver, 812 N.W.2d at 653 (“Since the penalty does not lead to an inference of gross disproportionality, we need not proceed to steps two and three of the analysis.”). 9 To recap, sentencing a repeat drug offender and habitual felon to fifteen years in prison with a mandatory three-year minimum does not violate either the due process clause or the cruel and unusual punishment clause of the Iowa Constitution.

2021This argument is quickly dispelled when Lyle is read in its entirety because Lyle confirms the holding has “no application to sentencing laws affecting adult offenders.” 854 N.W.2d at 403 . “[T]he line between being a juvenile and an adult was drawn for cruel and unusual punishment purposes at eighteen years of age.” State v. Seats, 865 N.W.2d 545, 556 (Iowa 2015) (discussing Roper v. Simmons, 543 U.S. 551, 574 (2005)).

2016See Seats, 865 N.W.2d at 558 . 11 A year after deciding Ragland, the court considered Lyle, premised upon a juvenile offender’s cruel-and-unusual-punishment challenge to his sentence of ten years in prison with a mandatory minimum term of seven years for a nonhomicide offense.

2017See id. at 546–47.

2017See id. at 546–47.

2017See Alexander v. United States, 509 U.S. 544 , 113 S. Ct. 2766 , 125 L.

2017See Alexander v. United States, 509 U.S. 544 , 113 S. Ct. 2766 , 125 L.

2017See Hoyman, 863 N.W.2d at 18 .

2017See Hoyman, 863 N.W.2d at 18 .

2009But see State v. Spriggs, 754 So.2d 84, 84 (Fla.Dist.Ct.App.2000) (finding motion to correct an illegal sentence not proper vehicle for bringing a cruel-and-unusual-punishment claim); Trevino v. State, 174 S.W.3d 925, 927-28 (Tex.Ct.App.2005) (same).

2009Ct. App. 2000) (finding motion to correct an illegal sentence not proper vehicle for bringing a cruel-and- unusual-punishment claim); Trevino v. State, 174 S.W.3d 925 , 927–28 (Tex. Ct. App. 2005) (same).

2025See State v. Laffey, 600 N.W.2d 57 , 61–62 (Iowa 1999) (rejecting a cruel-and-unusual-punishment challenge to an identical prison sentence for identical convictions, with an even greater mandatory minimum).

2021This argument is quickly dispelled when Lyle is read in its entirety because Lyle confirms the holding has “no application to sentencing laws affecting adult offenders.” 854 N.W.2d at 403 . “[T]he line between being a juvenile and an adult was drawn for cruel and unusual punishment purposes at eighteen years of age.” State v. Seats, 865 N.W.2d 545, 556 (Iowa 2015) (discussing Roper v. Simmons, 543 U.S. 551, 574 (2005)).

2018Id. at 785-6 ; see also State v. Ramirez , 597 N.W.2d 795 (Iowa 1999) (overruled on other grounds by Bruegger , 773 N.W.2d at 871-72 ). 3 In State v. Roby , our supreme court rejected a categorical challenge to the seventeen-and-a-half-year sentence applied to a juvenile offender. 897 N.W.2d 127 , 148 (Iowa 2017).

2018Id. at 785-6 ; see also State v. Ramirez , 597 N.W.2d 795 (Iowa 1999) (overruled on other grounds by Bruegger , 773 N.W.2d at 871-72 ). 3 In State v. Roby , our supreme court rejected a categorical challenge to the seventeen-and-a-half-year sentence applied to a juvenile offender. 897 N.W.2d 127 , 148 (Iowa 2017).

2017In State v. Ragland, 836 N.W.2d 107, 115 (Iowa 2013), our supreme court, in interpreting Miller, stated, “Miller requires courts to establish a procedure providing for an individualized sentencing hearing tailored to the unique attributes of juveniles when prosecuted as adults for homicide and facing a sentence of life without parole.” Our supreme court extended this rule under our state constitution: “[W]e conclude all mandatory minimum sentences of imprisonment for youthful offenders are unconstitutional under the cruel and unusual punishment clause in article I, section 17 of our constituti

2017Kimpton first contends his claim was not time-barred, relying upon Veal v. State, 779 N.W.2d 63, 64-65 (Iowa 2010), wherein the court reiterated that a claim of an illegal sentence may be raised at any time, and because a cruel-and- unusual-punishment challenge amounts to a claim of an illegal sentence, “the time restrictions in Iowa Code section 822.3 do not apply.” The State agrees, as do we, so we proceed to the next issue.

2016In all of those decisions, our court relied on State v. Tripp, 776 N.W.2d 855, 858-59 (Iowa 2010), which held a defendant’s cruel-and-unusual- punishment challenge was not ripe because the defendant was still serving a probationary term and was not yet serving the section 903B.1 special parole sentence.

2015The Lyle court recognized “the sentencing of juveniles according to statutorily required mandatory minimums does not adequately serve the legitimate penological objectives in light of the child’s categorically diminished culpability” and also recognized “the rehabilitative objective [for juveniles] can be inhibited by mandatory minimum sentences.” 854 N.W.2d at 398-400 ; see also State v. Pearson, 836 N.W.2d 88, 99 (Iowa 2013) (Cady, C.J., concurring specially) (stating the gravity of the offense does not affect the applicability of the juvenile’s rights under the Iowa constitution).

2014See State v. Harkins, 786 N.W.2d 498, 507-508 (Iowa Ct. App. 2009). 8 Jensen is seeking specific enforcement of the plea agreement or the sentencing order on constitutional grounds, he is challenging the sentence, thus keeping the argument within chapter 822.

2014The State specifically noted in its brief that the supreme court had not, at the time, held all mandatory minimums applied to juveniles were unconstitutional under the Iowa Constitution. 1 See North Carolina v. Alford, 400 U.S. 25, 37 (1970) (providing a defendant may “consent to the imposition of a prison sentence even if he is unwilling or unable to admit to his participation in the acts constituting the crime”). 3 Our supreme court has now decided that “all mandatory minimum sentences of imprisonment for youthful offenders are unconstitutional under the cruel and unusual punishment clause i

2014The State specifically noted in its brief that the supreme court had not, at the time, held all mandatory minimums applied to juveniles were unconstitutional under the Iowa Constitution. 1 See North Carolina v. Alford, 400 U.S. 25, 37 (1970) (providing a defendant may “consent to the imposition of a prison sentence even if he is unwilling or unable to admit to his participation in the acts constituting the crime”). 3 Our supreme court has now decided that “all mandatory minimum sentences of imprisonment for youthful offenders are unconstitutional under the cruel and unusual punishment clause i

2013See State v. Ragland, 812 N.W.2d 654, 659 (Iowa 2012).

2013See State v. Ragland, 812 N.W.2d 654, 659 (Iowa 2012).