State v. Null
SummaryOriginal

Summary

2013 | State Juristiction

State v. Null

Keywords juvenile sentencing; Miller v. Alabama; Graham v. Florida; Iowa Supreme Court; life without parole; juvenile life without parole

Abstract

In State v. Null, the Iowa Supreme Court remanded a juvenile defendant's case for resentencing after he was convicted of second-degree murder and first-degree robbery and sentenced to 75 years in prison. The Court ruled that the length of the multiple sentences, when combined, triggered protections under Miller v. Alabama because they resulted in a "de facto" life sentence. The Court ruled that under the Iowa Constitution, lower courts were required to apply the rules under Roper v. Simmons, Graham v. Florida, and Miller v. Alabama when sentencing juveniles to lengthy prison sentences.

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Abstract

In State v. Null, the Iowa Supreme Court remanded a juvenile defendant's case for resentencing after he was convicted of second-degree murder and first-degree robbery and sentenced to 75 years in prison. The Court ruled that the length of the multiple sentences, when combined, triggered protections under Miller v. Alabama because they resulted in a "de facto" life sentence. The Court ruled that under the Iowa Constitution, lower courts were required to apply the rules under Roper v. Simmons, Graham v. Florida, and Miller v. Alabama when sentencing juveniles to lengthy prison sentences.

Summary

In State v. Null, the Iowa Supreme Court addressed the sentencing of a juvenile defendant convicted of second-degree murder and first-degree robbery. The defendant received a 75-year prison sentence. The Court concluded that the cumulative length of the sentences constituted a "de facto" life sentence, thereby triggering the protections outlined in Miller v. Alabama. This ruling established that Iowa courts are obligated to consider the principles established in Roper v. Simmons, Graham v. Florida, and Miller v. Alabama when imposing lengthy prison sentences on juvenile offenders under the Iowa Constitution.

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Abstract

In State v. Null, the Iowa Supreme Court remanded a juvenile defendant's case for resentencing after he was convicted of second-degree murder and first-degree robbery and sentenced to 75 years in prison. The Court ruled that the length of the multiple sentences, when combined, triggered protections under Miller v. Alabama because they resulted in a "de facto" life sentence. The Court ruled that under the Iowa Constitution, lower courts were required to apply the rules under Roper v. Simmons, Graham v. Florida, and Miller v. Alabama when sentencing juveniles to lengthy prison sentences.

Summary

In the case of State v. Null, the Iowa Supreme Court ordered a new sentencing hearing for a juvenile defendant convicted of second-degree murder and first-degree robbery. The defendant had been sentenced to 75 years in prison. The Court determined that the combined length of the sentences constituted a "de facto" life sentence, triggering protections under the landmark case Miller v. Alabama. The Court concluded that the Iowa Constitution mandated that lower courts apply the principles established in Roper v. Simmons, Graham v. Florida, and Miller v. Alabama when imposing lengthy prison sentences on juveniles.

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Abstract

In State v. Null, the Iowa Supreme Court remanded a juvenile defendant's case for resentencing after he was convicted of second-degree murder and first-degree robbery and sentenced to 75 years in prison. The Court ruled that the length of the multiple sentences, when combined, triggered protections under Miller v. Alabama because they resulted in a "de facto" life sentence. The Court ruled that under the Iowa Constitution, lower courts were required to apply the rules under Roper v. Simmons, Graham v. Florida, and Miller v. Alabama when sentencing juveniles to lengthy prison sentences.

Summary

In the case of State v. Null, the Iowa Supreme Court sent a juvenile defendant's case back for a new sentencing hearing. The defendant had been found guilty of second-degree murder and first-degree robbery and given a 75-year prison sentence. The Court decided that this combined sentence was essentially a life sentence, even though it wasn't explicitly called that. This raised concerns about the constitutionality of the sentence under the Miller v. Alabama case, which sets guidelines for sentencing juveniles.

The Iowa Supreme Court ruled that Iowa's Constitution requires lower courts to consider specific rules about sentencing juveniles when imposing long prison sentences. These rules are based on the Supreme Court cases of Roper v. Simmons, Graham v. Florida, and Miller v. Alabama.

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Abstract

In State v. Null, the Iowa Supreme Court remanded a juvenile defendant's case for resentencing after he was convicted of second-degree murder and first-degree robbery and sentenced to 75 years in prison. The Court ruled that the length of the multiple sentences, when combined, triggered protections under Miller v. Alabama because they resulted in a "de facto" life sentence. The Court ruled that under the Iowa Constitution, lower courts were required to apply the rules under Roper v. Simmons, Graham v. Florida, and Miller v. Alabama when sentencing juveniles to lengthy prison sentences.

Summary

A young person in Iowa was found guilty of murder and robbery. The judge sentenced him to 75 years in prison. The Iowa Supreme Court said that this sentence was too long, especially for a young person. The Court said that the sentence was basically a "life sentence" because it was so long. They said that judges must consider special rules when sentencing young people because they are still developing. These rules protect young people from being sentenced to extremely long prison terms.

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Footnotes and Citation

Cite

State v. Null, 836 N.W.2d 41 (Iowa 2013)

Highlights