A divided Iowa Supreme Court has ruled that juveniles can never be sentenced to life without parole.
The Supreme Court had previously left open the possibility for a life without parole sentence for juveniles who committed murder and showed “irreparable corruption,” or no possibility of ever being reformed.
But in a ruling on the case involving 17-year-old Isaiah Sweet of Manchester, who admitted to killing his grandparents, the court ruled 4-3 that life sentences without parole for juveniles violate the Iowa Constitution.
The ruling says: “We should not ask our district court judges to predict future prospects for maturation and rehabilitation when highly trained professionals say such predictions are impossible. In sum, we conclude that sentencing courts should not be required to make speculative up-front decisions on juvenile offenders’ prospects for rehabilitation because they lack adequate predictive information supporting such a decision. 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.”
Justices Brent Appel, David Wiggins, Mark Cady and Daryl Hecht voted in the majority, and ordered a new sentence for Sweet. The ruling did not that it does not guarantee parole for a juvenile, but says “The determination of irredeemable corruption, however, must be made when the information is available to make that determination and not at a time when the juvenile character is a work in progress.”
Justice Edward Mansfield wrote one of two dissents in the case. “More is needed before we strike down a legislatively authorized sentence—especially one the general assembly reauthorized by large majorities in both houses just last year. The facts of this case, accompanied by the district court’s careful exercise of its sentencing discretion, allow the LWOP sentence in this particular case to be upheld. Regardless of my personal views on how this defendant should be sentenced, I do not believe the sentence here is unconstitutional because it violates the cruel and unusual punishment clause of the United States or Iowa Constitutions,” Mansfield wrote.
Mansfield says there remains a consensus in favor of continuing to make life without parole sentences available for juvenile murderers. He says that is exemplified by the actions of the legislature last year and by the similar actions of twenty-two other states.
Justice Bruce Zager also wrote a dissenting opinion. He says: “This court has repeatedly demonstrated that, in practice, it is unwilling to uphold any sentence of life without parole for juvenile offenders—indeed, we are not even willing to uphold sentences that are merely the functional equivalent of life without parole.” Zager says they are not asking the district court to do the impossible in making decisions on these cases, as they make these types of decisions “with distinction on a daily basis.”
Zager says adopting a rule that not juvenile should be sentenced to life without parole eliminates the district court’s sentencing obligations and any “effective appellate review.”
Justice Thomas Waterman joined both dissenting opinions.
Here’s the full ruling: Life Without Parole ruling PDF
Supreme Court hears case for and against juvenile life sentences