individualized sentencing hearing 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

2021See State v. Majors, 940 N.W.2d 372 , 385–86 (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 on a juvenile offender” and “[i]f the sentence imposed is within the statutory limits, . . . we review for an abuse of discretion”); see also Miller v. Alabama, 567 U.S. 460, 477 (2012) (identifying the “hallmark features” of youth)1; State v. Roby, 897 N.W.2d 127, 144 (Iowa 2017) (“We endorse the five factors identified in Miller as guideposts for courts to follow.

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);.

2017In Null, 836 N.W.2d at 71 , as well as State v. Pearson, 836 N.W.2d 88, 96 (Iowa 2013), and State v. Ragland, 836 N.W.2d 107, 121 (Iowa 2013), the court created a constitutional right to an individualized sentencing hearing for juveniles sentenced to a lengthy term of years without the meaningful opportunity for release.

2018In State v. Pearson, we similarly held that the individualized sentencing requirement set forth in Miller applied under the Iowa Constitution to a juvenile offender’s sentence of consecutive terms totaling thirty-five years imprisonment without parole eligibility for nonhomicide offenses. 836 N.W.2d 88, 96 (Iowa 2013).

2018In State v. Pearson , we similarly held that the individualized sentencing requirement set forth in Miller applied under the Iowa Constitution to a juvenile offender's sentence of consecutive terms totaling thirty-five years imprisonment without parole eligibility for nonhomicide offenses. 836 N.W.2d 88 , 96 (Iowa 2013).

2025As the supreme court has held, this claim cannot really be brought through a PCR action, and we have to treat the district court papers as a motion to correct an illegal sentence. 4 argues the holdings of Miller v. Alabama, 567 U.S. 460 (2012), Graham v. Florida, 560 U.S.48 (2010), State v. Sweet, 879 N.W.2d 811 (Iowa 2016), and State v. Ragland, 836 N.W.2d 107 (2013) prohibit imposing a mandatory punishment on a young adult offender—here twenty years of age—and instead require the district court to hold an individualized sentencing hearing before imposing any sentence.

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

2025As the supreme court has held, this claim cannot really be brought through a PCR action, and we have to treat the district court papers as a motion to correct an illegal sentence. 4 argues the holdings of Miller v. Alabama, 567 U.S. 460 (2012), Graham v. Florida, 560 U.S.48 (2010), State v. Sweet, 879 N.W.2d 811 (Iowa 2016), and State v. Ragland, 836 N.W.2d 107 (2013) prohibit imposing a mandatory punishment on a young adult offender—here twenty years of age—and instead require the district court to hold an individualized sentencing hearing before imposing any sentence.

2021Recognizing at the onset that her position is contrary to existing precedent, Smith urges individualized sentencing hearings should be mandated for “all crimes committed by juveniles.” But, in State v. Propps, the Iowa Supreme Court “decline[d] to extend the requirement of a Miller 4 An individualized sentencing hearing requires the court to consider several factors: (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 c

2021Analysis On appeal, Aron first argues he was prejudiced “as a thoughtful consideration of the factors related to juvenile criminal defendants would have likely resulted in a less restrictive sentencing alternative.” He requests his case “be reversed and remanded for an individualized sentencing hearing employing the factors articulated in Miller v. Alabama.” He recognizes that our supreme court “has previously determined that individualized sentencing is not required for crimes committed by juveniles when indeterminate sentences are ordered.” See State v. Propps, 897 N.W.2d 91, 104 (Iowa 2017)

2021Recognizing at the onset that her position is contrary to existing precedent, Smith urges individualized sentencing hearings should be mandated for “all crimes committed by juveniles.” But, in State v. Propps, the Iowa Supreme Court “decline[d] to extend the requirement of a Miller 4 An individualized sentencing hearing requires the court to consider several factors: (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 c

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

2021See State v. Majors, 940 N.W.2d 372 , 385–86 (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 on a juvenile offender” and “[i]f the sentence imposed is within the statutory limits, . . . we review for an abuse of discretion”); see also Miller v. Alabama, 567 U.S. 460, 477 (2012) (identifying the “hallmark features” of youth)1; State v. Roby, 897 N.W.2d 127, 144 (Iowa 2017) (“We endorse the five factors identified in Miller as guideposts for courts to follow.

2025As the supreme court has held, this claim cannot really be brought through a PCR action, and we have to treat the district court papers as a motion to correct an illegal sentence. 4 argues the holdings of Miller v. Alabama, 567 U.S. 460 (2012), Graham v. Florida, 560 U.S.48 (2010), State v. Sweet, 879 N.W.2d 811 (Iowa 2016), and State v. Ragland, 836 N.W.2d 107 (2013) prohibit imposing a mandatory punishment on a young adult offender—here twenty years of age—and instead require the district court to hold an individualized sentencing hearing before imposing any sentence.

2018In Sweet , we adopted "a categorical rule that juvenile offenders may not be sentenced to life without the possibility of parole." 879 N.W.2d at 839 . 6 *167 Crooks asks us to "take the next logical step and define at what age a child may be subject to adult prosecution and punishment" by adopting a categorical bar on sentencing an eighteen-year-old in adult court for a crime committed at age thirteen.

2016See State v. Louisell, 865 N.W.2d 590 (Iowa 2015); State v. Seats, 865 N.W.2d 545 (Iowa 2015); State v. Lyle, 854 N.W.2d 378 (Iowa 2014); State v. Null, 836 N.W.2d 41 (Iowa 2013); State v. Pearson, 836 N.W.2d 88 (Iowa 2013); State v. Ragland, 836 N.W.2d 107 (Iowa 2013).

2016See id.

2019But “if the district court follows the sentencing procedure we have identified and a statute authorizes the sentence ultimately imposed, then our review is for abuse of discretion; we ask whether there is ‘evidence [that] supports the sentence.’ ” Id. (alteration in original) (quoting State v. Seats, 865 N.W.2d 545, 553 (Iowa 2015)).

2016See State v. Louisell, 865 N.W.2d 590 (Iowa 2015); State v. Seats, 865 N.W.2d 545 (Iowa 2015); State v. Lyle, 854 N.W.2d 378 (Iowa 2014); State v. Null, 836 N.W.2d 41 (Iowa 2013); State v. Pearson, 836 N.W.2d 88 (Iowa 2013); State v. Ragland, 836 N.W.2d 107 (Iowa 2013).

2020See Bonilla v. Iowa Bd. of Parole, 930 N.W.2d 751, 771 (Iowa 2019). 4 Additionally, an individualized sentencing hearing is not afforded “to juvenile defendants who are not subject to a mandatory minimum period of incarceration.” State v. Crooks, 911 N.W.2d 153, 172 (Iowa 2018) (quoting Propps, 897 N.W.2d at 104 ). 9 We conclude McGee has not shown he was subjected to cruel and unusual punishment.

2020See Bonilla v. Iowa Bd. of Parole, 930 N.W.2d 751, 771 (Iowa 2019). 4 Additionally, an individualized sentencing hearing is not afforded “to juvenile defendants who are not subject to a mandatory minimum period of incarceration.” State v. Crooks, 911 N.W.2d 153, 172 (Iowa 2018) (quoting Propps, 897 N.W.2d at 104 ). 9 We conclude McGee has not shown he was subjected to cruel and unusual punishment.

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408; see also Falcon v. State, 162 So.3d 954, 963 (Fla.2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resen-tenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 164 So.3d 117, 118 (Fla.Dist.Ct.App.2015) (applying the Horsley analysis to a defendant who had been sentenced to life without parole pr e-Miller and remanding for re-se

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408 ; see also Falcon v. State, ___ So. 3d ___, ___, 2015 WL 1239365 , at *8–9 (Fla. Mar. 19, 2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resentenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 27 ___ So. 3d ___, ___ , 2015 WL 2137783, at *1 (Fla. Dist.

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408; see also Falcon v. State, 162 So.3d 954, 963 (Fla.2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resen-tenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 164 So.3d 117, 118 (Fla.Dist.Ct.App.2015) (applying the Horsley analysis to a defendant who had been sentenced to life without parole pr e-Miller and remanding for re-se

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408 ; see also Falcon v. State, ___ So. 3d ___, ___, 2015 WL 1239365 , at *8–9 (Fla. Mar. 19, 2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resentenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 27 ___ So. 3d ___, ___ , 2015 WL 2137783, at *1 (Fla. Dist.

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408; see also Falcon v. State, 162 So.3d 954, 963 (Fla.2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resen-tenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 164 So.3d 117, 118 (Fla.Dist.Ct.App.2015) (applying the Horsley analysis to a defendant who had been sentenced to life without parole pr e-Miller and remanding for re-se

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408; see also Falcon v. State, 162 So.3d 954, 963 (Fla.2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resen-tenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 164 So.3d 117, 118 (Fla.Dist.Ct.App.2015) (applying the Horsley analysis to a defendant who had been sentenced to life without parole pr e-Miller and remanding for re-se

2015Ct. App. May 8, 2015) (applying the Horsley analysis to a defendant who had been sentenced to life without parole pre-Miller and remanding for resentencing consistent with the 2014 Florida legislation); Mares v. State, ___ So. 3d ___, ___, 2015 WL 2078179, at *1 (Fla. Dist.

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408; see also Falcon v. State, 162 So.3d 954, 963 (Fla.2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resen-tenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 164 So.3d 117, 118 (Fla.Dist.Ct.App.2015) (applying the Horsley analysis to a defendant who had been sentenced to life without parole pr e-Miller and remanding for re-se

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408; see also Falcon v. State, 162 So.3d 954, 963 (Fla.2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resen-tenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 164 So.3d 117, 118 (Fla.Dist.Ct.App.2015) (applying the Horsley analysis to a defendant who had been sentenced to life without parole pr e-Miller and remanding for re-se

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408; see also Falcon v. State, 162 So.3d 954, 963 (Fla.2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resen-tenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 164 So.3d 117, 118 (Fla.Dist.Ct.App.2015) (applying the Horsley analysis to a defendant who had been sentenced to life without parole pr e-Miller and remanding for re-se

2015The court concluded that “[o]n remand, the trial court should hold an individualized sentencing hearing pursuant to [the 2014 law].” Id. at 408 ; see also Falcon v. State, ___ So. 3d ___, ___, 2015 WL 1239365 , at *8–9 (Fla. Mar. 19, 2015) (concluding Miller should apply retroactively and any defendant whose sentence is invalidated by the retroactive application of Miller should be resentenced under the 2014 Florida legislation pursuant to Horsley); Cruz v. State, 27 ___ So. 3d ___, ___ , 2015 WL 2137783, at *1 (Fla. Dist.

2014In State v. Oliver, 812 N.W.2d 636, 651 (Iowa 2012), our supreme court clarified that defendants are entitled to bring an as-applied challenge, now known as a gross disproportionality challenge, to their sentences.