Miller factors in Iowa

2023See State v. Majors, 940 N.W.2d 372 , 386 (Iowa 2020) (stating the “sentencing court must consider the Miller/Lyle/Roby factors in an individualized sentencing hearing if it is contemplating imposing a mandatory minimum sentence 3 on a juvenile offender”); see also Miller v. Alabama, 567 U.S. 460, 477 (2012) (identifying the “hallmark features” of youth); State v. Roby, 897 N.W.2d 127, 144 (Iowa 2017) (endorsing the five factors in Miller “as guideposts for courts to follow”); State v. Lyle, 854 N.W.2d 378 , 404 n.10 (Iowa 2014) (adopting the Miller factors for resentencing of juvenile offende

2023See State v. Majors, 940 N.W.2d 372 , 386 (Iowa 2020) (stating the “sentencing court must consider the Miller/Lyle/Roby factors in an individualized sentencing hearing if it is contemplating imposing a mandatory minimum sentence 3 on a juvenile offender”); see also Miller v. Alabama, 567 U.S. 460, 477 (2012) (identifying the “hallmark features” of youth); State v. Roby, 897 N.W.2d 127, 144 (Iowa 2017) (endorsing the five factors in Miller “as guideposts for courts to follow”); State v. Lyle, 854 N.W.2d 378 , 404 n.10 (Iowa 2014) (adopting the Miller factors for resentencing of juvenile offende

2024He claims the court should have considered the Miller factors when determining an appropriate sentence.4 When a sentence is within statutory limits, we review the court’s sentencing decision for 4 The Miller factors consists of the age of the offender and the features of youthful behavior; the particular family and home environment that surround the youth; the circumstances relating to youth that may have played a role in the commission of the crime; the challenges for youthful offenders in navigating through the criminal process; and the possibility of rehabilitation and the capacity for chan

2024He claims the court should have considered the Miller factors when determining an appropriate sentence.4 When a sentence is within statutory limits, we review the court’s sentencing decision for 4 The Miller factors consists of the age of the offender and the features of youthful behavior; the particular family and home environment that surround the youth; the circumstances relating to youth that may have played a role in the commission of the crime; the challenges for youthful offenders in navigating through the criminal process; and the possibility of rehabilitation and the capacity for chan

2017In State v. Ragland, we said that a sentencing court “must consider” the following Miller factors when a sentencing a juvenile to a possible sentence of life without parole: (1) the “chronological age” of the youth and the features of youth, including “immaturity, impetuosity, and failure to appreciate risks and consequences”; (2) the “family and home environment” that surrounded the youth; (3) “the circumstances of the . . . offense, including the extent of [the youth’s] participation in the conduct and the way familial and peer pressures may have affected [the youth]”; (4) the “incompetencie

2017In State v. Ragland, we said that a sentencing court “must consider” the following Miller factors when a sentencing a juvenile to a possible sentence of life without parole: (1) the “chronological age” of the youth and the features of youth, including “immaturity, impetuosity, and failure to appreciate risks and consequences”; (2) the “family and home environment” that surrounded the youth; (3) “the circumstances of the . . . offense, including the extent of [the youth’s] participation in the conduct and the way familial and peer pressures may have affected [the youth]”; (4) the “incompetencie

2021As a juvenile during the commission of her offenses, had the crimes imposed a mandatory minimum sentence, our cases require that Smith receive an individualized sentencing hearing and that the district court apply the Miller factors.4 See State v. Null, 836 N.W.2d 41, 76-77 (Iowa 2013) (“[A] 52.5-year minimum prison term for a juvenile based on the aggregation of mandatory minimum sentences . . . triggers the protections . . . afforded under Miller,” where the Supreme Court required an examination of the “hallmark features of youth” before imposing a life sentence);.

2021As a juvenile during the commission of her offenses, had the crimes imposed a mandatory minimum sentence, our cases require that Smith receive an individualized sentencing hearing and that the district court apply the Miller factors.4 See State v. Null, 836 N.W.2d 41, 76-77 (Iowa 2013) (“[A] 52.5-year minimum prison term for a juvenile based on the aggregation of mandatory minimum sentences . . . triggers the protections . . . afforded under Miller,” where the Supreme Court required an examination of the “hallmark features of youth” before imposing a life sentence);.

2024In State v. Propps, the Iowa Supreme Court held a juvenile defendant was not entitled to a Miller hearing where the sentence for a criminal offense has no mandatory minimum period of incarceration and the defendant is immediately eligible for parole. 897 N.W.2d 91, 101 (Iowa 2017).

2024In State v. Propps, the Iowa Supreme Court held a juvenile defendant was not entitled to a Miller hearing where the sentence for a criminal offense has no mandatory minimum period of incarceration and the defendant is immediately eligible for parole. 897 N.W.2d 91, 101 (Iowa 2017).

2023See State v. Majors, 940 N.W.2d 372 , 386 (Iowa 2020) (stating the “sentencing court must consider the Miller/Lyle/Roby factors in an individualized sentencing hearing if it is contemplating imposing a mandatory minimum sentence 3 on a juvenile offender”); see also Miller v. Alabama, 567 U.S. 460, 477 (2012) (identifying the “hallmark features” of youth); State v. Roby, 897 N.W.2d 127, 144 (Iowa 2017) (endorsing the five factors in Miller “as guideposts for courts to follow”); State v. Lyle, 854 N.W.2d 378 , 404 n.10 (Iowa 2014) (adopting the Miller factors for resentencing of juvenile offende

2023See State v. Majors, 940 N.W.2d 372 , 386 (Iowa 2020) (stating the “sentencing court must consider the Miller/Lyle/Roby factors in an individualized sentencing hearing if it is contemplating imposing a mandatory minimum sentence 3 on a juvenile offender”); see also Miller v. Alabama, 567 U.S. 460, 477 (2012) (identifying the “hallmark features” of youth); State v. Roby, 897 N.W.2d 127, 144 (Iowa 2017) (endorsing the five factors in Miller “as guideposts for courts to follow”); State v. Lyle, 854 N.W.2d 378 , 404 n.10 (Iowa 2014) (adopting the Miller factors for resentencing of juvenile offende

2024The Iowa Supreme Court concluded, “Under Propps, no hearing 6 on the Miller/Lyle factors was required to sentence Crooks to prison with immediate eligibility for parole.” Id.; accord State v. Shade, No. 17-1541, 2018 WL 3654856 , at *2 (Iowa Ct. App. Aug. 1, 2018) (“More recently, the supreme court concluded the district court was not required to conduct a Miller hearing where the juvenile defendant could have been subject to a minimum sentence but where the district court declined to impose a minimum sentence.” (citing Crooks, 911 N.W.2d at 173 )).

2024The Iowa Supreme Court concluded, “Under Propps, no hearing 6 on the Miller/Lyle factors was required to sentence Crooks to prison with immediate eligibility for parole.” Id.; accord State v. Shade, No. 17-1541, 2018 WL 3654856 , at *2 (Iowa Ct. App. Aug. 1, 2018) (“More recently, the supreme court concluded the district court was not required to conduct a Miller hearing where the juvenile defendant could have been subject to a minimum sentence but where the district court declined to impose a minimum sentence.” (citing Crooks, 911 N.W.2d at 173 )).

2021A. Standard of Review “Challenges to the sufficiency of the evidence are reviewed for errors at law.” State v. Hansen, 750 N.W.2d 111, 112 (Iowa 2008).

2014State v. Hansen, 750 N.W.2d 111, 112 (Iowa 2008).

2017The district court concluded the IDOC’s new interpretation conflicted with Holm, 767 N.W.2d at 414, 418 , and that the retroactive application of the 2016 policy to Miller violated the Ex Post Facto Clauses of the United States and Iowa Constitutions.

2017The district court concluded the IDOC’s new interpretation conflicted with Holm, 767 N.W.2d at 414, 418 , and that the retroactive application of the 2016 policy to Miller violated the Ex Post Facto Clauses of the United States and Iowa Constitutions.

2016See Lyle, 854 N.W.2d at 381 (discussing Null, 836 N.W.2d at 72 ; State v. Pearson, 836 N.W.2d 88, 96-97 (Iowa 2013); and State v. Ragland, 836 N.W.2d 107, 117 (Iowa 2013)).

2016See Lyle, 854 N.W.2d at 381 (discussing Null, 836 N.W.2d at 72 ; State v. Pearson, 836 N.W.2d 88, 96-97 (Iowa 2013); and State v. Ragland, 836 N.W.2d 107, 117 (Iowa 2013)).

2016Bank v. Pro-Build Holdings, Inc., 856 N.W.2d 892, 893 (Iowa 2014) (noting our court appropriately deferred to the supreme court on whether to extend the doctrine of an implied warranty of workmanlike construction).

2015Bank v. Pro-Build Holdings, Inc., 856 N.W.2d 892, 893 (Iowa 2014) (noting our court appropriately deferred to supreme court on whether to extend the doctrine of an implied warranty of workmanlike construction).

2015See, e.g., United States v. Guerrero, 560 Fed.Appx. 110, 112 (2d Cir.2014) (affirming the defendant’s resentenc-ing to life without parole because “[t]he district court properly considered all of the Miller factors”); Copeland v. State, 129 So.3d 508, 511 (Fla.Dist.Ct.App.2014) (“[T]he sentencing court conducted an individualized mitigation inquiry, considering several potential mitigating factors before finding that life without the possibility of parole was, nevertheless, appropriate in this case.

2015See, e.g., United States v. Guerrero, 560 Fed.Appx. 110, 112 (2d Cir.2014) (affirming the defendant’s resentenc-ing to life without parole because “[t]he district court properly considered all of the Miller factors”); Copeland v. State, 129 So.3d 508, 511 (Fla.Dist.Ct.App.2014) (“[T]he sentencing court conducted an individualized mitigation inquiry, considering several potential mitigating factors before finding that life without the possibility of parole was, nevertheless, appropriate in this case.

2015See, e.g., United States v. Guerrero, 560 Fed.Appx. 110, 112 (2d Cir.2014) (affirming the defendant’s resentenc-ing to life without parole because “[t]he district court properly considered all of the Miller factors”); Copeland v. State, 129 So.3d 508, 511 (Fla.Dist.Ct.App.2014) (“[T]he sentencing court conducted an individualized mitigation inquiry, considering several potential mitigating factors before finding that life without the possibility of parole was, nevertheless, appropriate in this case.

2015See, e.g., United States v. Guerrero, 560 Fed.Appx. 110, 112 (2d Cir.2014) (affirming the defendant’s resentenc-ing to life without parole because “[t]he district court properly considered all of the Miller factors”); Copeland v. State, 129 So.3d 508, 511 (Fla.Dist.Ct.App.2014) (“[T]he sentencing court conducted an individualized mitigation inquiry, considering several potential mitigating factors before finding that life without the possibility of parole was, nevertheless, appropriate in this case.

2018“We review for an ‘abuse of discretion,’ our most deferential standard, ‘if the sentence is within the statutory limits.’ We review for ‘correction of errors at law,’ an intermediate standard, ‘when the 4 defendant challenges the legality of a sentence on nonconstitutional grounds.’” State v. Roby, 897 N.W.2d 127, 137 (Iowa 2017) (quoting State v. Seats, 865 N.W.2d 545 , 552–53 (Iowa 2015)).

2018“We review for an ‘abuse of discretion,’ our most deferential standard, ‘if the sentence is within the statutory limits.’ We review for ‘correction of errors at law,’ an intermediate standard, ‘when the 4 defendant challenges the legality of a sentence on nonconstitutional grounds.’” State v. Roby, 897 N.W.2d 127, 137 (Iowa 2017) (quoting State v. Seats, 865 N.W.2d 545 , 552–53 (Iowa 2015)).

2025In revoking the deferred judgment and imposing a prison sentence, the district court expressly considered Miller’s mental-health needs but found them outweighed by Miller’s failure to rehabilitate, his choice not to timely seek treatment when given a second (and third) chance, his need for a structured environment, and his inability to control his violent impulses. “[T]he decision of the district court to impose a particular sentence within the statutory limits is cloaked with a strong presumption in its favor, and will only be overturned for an abuse of discretion or the consideration of inap

2024“We do not decide the sentence we would have imposed, but whether the sentence imposed was unreasonable.” State v. Hopkins, 860 N.W.2d 550, 554 (Iowa 2015).

2024“We do not decide the sentence we would have imposed, but whether the sentence imposed was unreasonable.” State v. Hopkins, 860 N.W.2d 550, 554 (Iowa 2015).

2023See State v. Sailer, 587 N.W.2d 756, 761 (Iowa 1998) (ruling a victim impact statement is construed “to enable the victim to fully detail the impact of the offense, regardless of whether certain elements of a crime have been established”). “[W]hen a challenge is made to a criminal sentence on the basis that the court improperly considered unproven criminal activity, the issue presented is simply one of the sufficiency of the record to establish the matters relied on.” State v. Grandberry, 619 N.W.2d 399, 401 (Iowa 2000) (citation omitted).

2023See State v. Sailer, 587 N.W.2d 756, 761 (Iowa 1998) (ruling a victim impact statement is construed “to enable the victim to fully detail the impact of the offense, regardless of whether certain elements of a crime have been established”). “[W]hen a challenge is made to a criminal sentence on the basis that the court improperly considered unproven criminal activity, the issue presented is simply one of the sufficiency of the record to establish the matters relied on.” State v. Grandberry, 619 N.W.2d 399, 401 (Iowa 2000) (citation omitted).

2022Ultimately, “attorneys are officers of the court, and ‘when they address the judge solemnly upon a matter before the court, their declarations are virtually made under oath.’ ” Holloway v. Arkansas, 435 U.S. 475, 486 (1978) (quoting State v. Brazile, 75 So. 2d 856 , 860–61 (La. 1954)).

2020See Meier v. Senecaut, 641 N.W.2d 532, 540 (Iowa 2002).