The Iowa Supreme Court decided last week that life without parole for juveniles (JLWOP) is unconstitutional, thereby extending the holdings from Miller and Montgomery a step further.
In Miller, the U.S. Supreme Court held that juveniles could not be sentenced to life without parole under a mandatory statute; instead, the trial court must take into consideration the inherent malleability of a developing juvenile personality when crafting an appropriate sentence. Montgomery made the rule in Miller retrospective in application. The court wrote that a juvenile must be found to be “irreparably corrupted” for a judge to appropriately sentence a juvenile to a life sentence.
The case before the Iowa court, State v. Sweet, involved Isaiah Sweet, who was 17 years old when he killed his grandparents. He alleged they were extremely emotionally abusive to him throughout childhood, and psychiatric experts testified that he was closer in development to a 12-, 13-, or 14-year-old. The State of Iowa argued that “nothing in Sweet’s background, including his chronological age, his family and home environment, or the incompetencies of youth, support a lesser sentence than life without the possibility of parole.” In addition, the state argued “there was no evidence the defendant can ever be rehabilitated.”
Not only did the state Supreme Court reject the state’s argument, but it found that there was “little to be gained by allowing further caselaw development on the question of whether a juvenile may ever receive a sentence of life without the possibility of parole.” The punishment is already only permitted under the Constitution for “the rarest” of cases. And the Iowa court found that “the enterprise of identifying which juvenile offenders are irretrievable at the time of trial is simply too speculative and likely impossible given what we now know about the timeline of brain development and related prospects for self-regulation and rehabilitation.” Even expert psychiatric witnesses in the case testified that they would be unable to determine incorrigibility before Sweet turned 25 years old. One expert witness testified that, “the earliest a determination could be made regarding Sweet’s potential for rehabilitation was age thirty.”
The Iowa court explicitly compared life without the possibility of parole to “a sanction akin to the death penalty,” which juveniles have been protected from receiving since 2005.
Ultimately, the court ruled that “the parole board will be better able to discern whether the offender is irreparably corrupt after time has passed, after opportunities for maturation and rehabilitation have been provided, and after a record of success or failure in the rehabilitative process is available.” After all, the majority wrote, “the juvenile character is a work in progress.”