by Ryan J. Foley
IOWA CITY, Iowa — A divided Iowa Supreme Court on Friday banned judges from imposing life prison sentences without the possibility of parole on juveniles convicted of first-degree murder.
The court ruled 4-3 that the sentence amounts to cruel and unusual punishment under the Iowa Constitution. Even juveniles who commit the most heinous crimes should someday have the option of proving to the Iowa Board of Parole that they have been rehabilitated and are fit for release, Justice Brent Appel wrote for the majority.
Judges are simply unable to predict at the time of trial which youthful offenders have reliable prospects for turning their lives around, he said, adding that the young offenders’ brains are still developing.
Justices ruled in the case of Isaiah Sweet, who was 17 when he killed his grandparents at their home in Manchester in 2012.
A judge in 2014 sentenced Sweet to life in prison without parole, saying he was a cold-blooded murderer who had little chance of rehabilitation. Friday’s ruling overturns that sentence.
Appel wrote that the ruling doesn’t guarantee parole for juvenile offenders, and warned that those “who over time show irredeemable corruption will no doubt spend their lives in prison.” Those determinations, however, must be made by parole officials and not sentencing judges.
“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,” Appel wrote.
Dissenting Justice Edward Mansfield said the court was wrong to strike down a sentencing option that had been overwhelmingly reauthorized by Iowa lawmakers last year. He said the judge was correct to use his discretion to sentence Sweet to life for the premeditated murder of his grandparents, who had raised him since age 4.
States have been forced to rethink their punishments for juvenile offenders in recent years. The U.S. Supreme Court abolished automatic life sentences for juvenile offenders in 2012, saying judges must consider each offender’s ability to be rehabilitated at sentencing. The court kept the door open for judges to impose life-without-parole sentences on the rare offender whose crimes reflect “irreparable corruption.”
With bipartisan backing, Iowa Gov. Terry Branstad signed a law last year that retained the sentence as an option that judges could impose on juveniles convicted of murder.
Friday’s ruling makes Iowa the 19th state to ban life without parole sentences for juveniles either through legislation or courts, according to the Sentencing Project, an advocacy group that praised the ruling.
“It’s terrific news. It’s overdue but welcome nonetheless,” said Ashley Nellis, a senior research analyst for the group.
The Iowa Supreme Court is only the second state court after Massachusetts to outlaw such sentences based on the state constitution, said Shellie Knipfer, an assistant appellate defender who represented Sweet.
“It’s appropriate in light of the nature of juveniles and their continued development and the fact that we just don’t know at that time where their ultimate development will be,” she said. “The burden will still be upon the offender to show that they are rehabilitated at some later date.”