State v. Harrison
SummaryOriginal

Summary

State v. Harrison (2018) addresses applying the felony murder rule and life sentence to a juvenile offender in Iowa. Court rejects due process and cruel and unusual punishment claims.

2018 | State Juristiction

State v. Harrison

Keywords felony murder doctrine; juvenile offender; Iowa Supreme Court; cruel and unusual punishment; ineffective assistance of counsel; due process

Abstract

State v. Harrison (2018) involved Keyon Harrison, a 16-year-old convicted of first-degree murder under Iowa's felony murder rule. During a robbery attempt, Harrison's accomplice's gun went off, killing the victim. Harrison appealed, arguing the felony murder rule's application to juveniles violated his due process rights. He also challenged the life sentence as cruel and unusual punishment for a juvenile offender. Additionally, Harrison claimed his trial counsel was ineffective for failing to properly address jury instructions and evidence. The Iowa Supreme Court upheld both the conviction and sentence. The court reasoned the felony murder rule applied regardless of age and foreseeability wasn't a factor. They found life without parole with the possibility of early release didn't constitute cruel and unusual punishment. Lastly, the court concluded Harrison's trial counsel did not provide ineffective assistance.

Open Case as PDF

Abstract

State v. Harrison (2018) involved Keyon Harrison, a 16-year-old convicted of first-degree murder under Iowa's felony murder rule. During a robbery attempt, Harrison's accomplice's gun went off, killing the victim. Harrison appealed, arguing the felony murder rule's application to juveniles violated his due process rights. He also challenged the life sentence as cruel and unusual punishment for a juvenile offender. Additionally, Harrison claimed his trial counsel was ineffective for failing to properly address jury instructions and evidence. The Iowa Supreme Court upheld both the conviction and sentence. The court reasoned the felony murder rule applied regardless of age and foreseeability wasn't a factor. They found life without parole with the possibility of early release didn't constitute cruel and unusual punishment. Lastly, the court concluded Harrison's trial counsel did not provide ineffective assistance.

In the 2018 case of State v. Harrison, the Iowa Supreme Court addressed the application of the felony murder rule to juvenile offenders and the constitutionality of life sentences for such individuals. The case involved Keyon Harrison, a sixteen-year-old convicted of first-degree murder. During an attempted robbery, a firearm discharged by Harrison's accomplice resulted in the death of the victim.

Harrison appealed his conviction on several grounds. He argued that applying the felony murder rule to juveniles violated his right to due process, particularly given the lack of a foreseeability requirement. Furthermore, he challenged the constitutionality of his sentence - life imprisonment with the possibility of parole - asserting that it constituted cruel and unusual punishment for a juvenile. Lastly, Harrison alleged ineffective assistance of counsel, citing his trial attorney's failure to adequately address jury instructions and evidentiary matters.

The Iowa Supreme Court affirmed both Harrison's conviction and sentence. The court held that the state's felony murder rule applied irrespective of the defendant's age and did not necessitate a finding of foreseeability regarding the victim's death. Additionally, the court determined that a sentence of life imprisonment with the possibility of parole, even for a juvenile offender, did not violate the prohibition against cruel and unusual punishment. Finally, the court rejected Harrison's claim of ineffective assistance of counsel, concluding that his trial attorney's performance met the constitutional standard.

Open Case as PDF

Abstract

State v. Harrison (2018) involved Keyon Harrison, a 16-year-old convicted of first-degree murder under Iowa's felony murder rule. During a robbery attempt, Harrison's accomplice's gun went off, killing the victim. Harrison appealed, arguing the felony murder rule's application to juveniles violated his due process rights. He also challenged the life sentence as cruel and unusual punishment for a juvenile offender. Additionally, Harrison claimed his trial counsel was ineffective for failing to properly address jury instructions and evidence. The Iowa Supreme Court upheld both the conviction and sentence. The court reasoned the felony murder rule applied regardless of age and foreseeability wasn't a factor. They found life without parole with the possibility of early release didn't constitute cruel and unusual punishment. Lastly, the court concluded Harrison's trial counsel did not provide ineffective assistance.

The case of State v. Harrison (2018) centered around Keyon Harrison, a sixteen-year-old found guilty of first-degree murder under Iowa's felony murder rule. Harrison participated in a robbery attempt during which his accomplice's firearm discharged, resulting in the death of the victim. On appeal, Harrison argued that applying the felony murder rule to minors violated his constitutional right to due process. He further contested his sentence of life imprisonment, asserting it constituted cruel and unusual punishment for a juvenile offender. Additionally, Harrison claimed inadequate legal representation at trial due to his attorney's failure to properly address jury instructions and presented evidence.

The Iowa Supreme Court affirmed both the conviction and the sentence. The court determined that the felony murder rule's application was not contingent upon age and that the issue of foreseeability was irrelevant in this instance. They ruled that a sentence of life imprisonment with the possibility of parole did not meet the criteria for cruel and unusual punishment. Finally, the court rejected Harrison's claim of ineffective assistance of counsel.

Open Case as PDF

Abstract

State v. Harrison (2018) involved Keyon Harrison, a 16-year-old convicted of first-degree murder under Iowa's felony murder rule. During a robbery attempt, Harrison's accomplice's gun went off, killing the victim. Harrison appealed, arguing the felony murder rule's application to juveniles violated his due process rights. He also challenged the life sentence as cruel and unusual punishment for a juvenile offender. Additionally, Harrison claimed his trial counsel was ineffective for failing to properly address jury instructions and evidence. The Iowa Supreme Court upheld both the conviction and sentence. The court reasoned the felony murder rule applied regardless of age and foreseeability wasn't a factor. They found life without parole with the possibility of early release didn't constitute cruel and unusual punishment. Lastly, the court concluded Harrison's trial counsel did not provide ineffective assistance.

State v. Harrison (2018) was a court case about a teenager named Keyon Harrison, who was 16 years old when he was found guilty of first-degree murder. He was convicted because of Iowa's "felony murder rule." This rule says that if someone dies during a serious crime like a robbery, even if it's an accident, the people involved in the crime can be charged with murder.

Here's what happened: Harrison and another person tried to rob someone, and during the robbery, the other person's gun went off. This sadly killed the victim. Harrison argued that it wasn't fair to charge him with murder since he didn't pull the trigger and didn't expect anyone to die. He also said that being sentenced to life in prison was too harsh for someone his age. On top of that, he claimed his lawyer during the trial didn't do a good job explaining the legal rules and evidence to the jury.

The highest court in Iowa, the Iowa Supreme Court, ultimately decided that Harrison's conviction and sentence were fair. They said the felony murder rule applies to everyone, no matter their age, and it doesn't matter if the death was planned or not. They also decided that while a life sentence without the chance of parole might be cruel, Iowa's law allows for possible early release, so it wasn't considered cruel or unusual. Finally, the court disagreed that Harrison's lawyer did a bad job defending him.

Open Case as PDF

Abstract

State v. Harrison (2018) involved Keyon Harrison, a 16-year-old convicted of first-degree murder under Iowa's felony murder rule. During a robbery attempt, Harrison's accomplice's gun went off, killing the victim. Harrison appealed, arguing the felony murder rule's application to juveniles violated his due process rights. He also challenged the life sentence as cruel and unusual punishment for a juvenile offender. Additionally, Harrison claimed his trial counsel was ineffective for failing to properly address jury instructions and evidence. The Iowa Supreme Court upheld both the conviction and sentence. The court reasoned the felony murder rule applied regardless of age and foreseeability wasn't a factor. They found life without parole with the possibility of early release didn't constitute cruel and unusual punishment. Lastly, the court concluded Harrison's trial counsel did not provide ineffective assistance.

The Case: Keyon Harrison, a 16-year-old, was found guilty of a very serious crime called first-degree murder. This happened because Iowa has a rule called the "felony murder rule." Harrison was involved in a robbery where someone he was with shot and killed a person. Even though Harrison didn't pull the trigger, the court said he was still responsible because of this rule.

Harrison thought this was unfair and asked a higher court to look at his case again. He said the felony murder rule shouldn't apply to kids his age and that his punishment, spending life in prison, was too harsh. He also believed his lawyer didn't do a good enough job defending him at trial.

The Decision: The highest court in Iowa decided to keep the original decision. They said the felony murder rule applies to everyone, no matter how old they are. The court also said that life in prison, even though it sounds very long, wasn't too harsh of a punishment for Harrison. Lastly, they decided that Harrison's lawyer did do a good job representing him.

Open Case as PDF

Footnotes and Citation

Cite

State v. Harrison, 914 N.W.2d 178 (Iowa 2018)

Highlights