State v. Ragland
SimpleOriginal
2013 | State Juristiction

State v. Ragland

Keywords juvenile sentencing; de facto life without parole; juvenile life without parole; JLWOP; retroactive application of Miller v. Alabama; Miller v. Alabama; discretionary review

Abstract

This 2013 case before the Supreme Court of Iowa involved a juvenile offender who was tried as an adult, convicted of first-degree murder, and sentenced to life without parole. The defendant appealed for postconviction relief and eventually the Governor commuted his sentence to life without the possibility of parole for sixty years. The District Court for Pottawattamie County said the Governor's commutation was improper and resentenced the defendant to life with the possibility of parole after twenty-five years, making him immediately eligible for parole. The State requested discretionary review. The Supreme Court of Iowa held that under Miller v. Alabama applied retroactively to cases on direct and collateral review. The Court also held that the defendant's commuted sentence was the functional equivalent of a life without parole sentence, making it unconstitutional.

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Abstract

This 2013 case before the Supreme Court of Iowa involved a juvenile offender who was tried as an adult, convicted of first-degree murder, and sentenced to life without parole. The defendant appealed for postconviction relief and eventually the Governor commuted his sentence to life without the possibility of parole for sixty years. The District Court for Pottawattamie County said the Governor's commutation was improper and resentenced the defendant to life with the possibility of parole after twenty-five years, making him immediately eligible for parole. The State requested discretionary review. The Supreme Court of Iowa held that under Miller v. Alabama applied retroactively to cases on direct and collateral review. The Court also held that the defendant's commuted sentence was the functional equivalent of a life without parole sentence, making it unconstitutional.

Summary

This case, heard in 2013 by the Iowa Supreme Court, concerns a juvenile offender who was tried as an adult, convicted of first-degree murder, and sentenced to life without the possibility of parole. The defendant sought postconviction relief, culminating in the Governor commuting his sentence to life without the possibility of parole for sixty years. However, the Pottawattamie County District Court declared the Governor's commutation improper and resentenced the defendant to life with the possibility of parole after twenty-five years, making him immediately eligible for parole. The State then sought discretionary review.

The Iowa Supreme Court ruled that the Miller v. Alabama decision, which prohibits mandatory life without parole sentences for juveniles, applied retroactively to cases under both direct and collateral review. The Court further determined that the defendant's commuted sentence was effectively equivalent to a life without parole sentence, rendering it unconstitutional.

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Abstract

This 2013 case before the Supreme Court of Iowa involved a juvenile offender who was tried as an adult, convicted of first-degree murder, and sentenced to life without parole. The defendant appealed for postconviction relief and eventually the Governor commuted his sentence to life without the possibility of parole for sixty years. The District Court for Pottawattamie County said the Governor's commutation was improper and resentenced the defendant to life with the possibility of parole after twenty-five years, making him immediately eligible for parole. The State requested discretionary review. The Supreme Court of Iowa held that under Miller v. Alabama applied retroactively to cases on direct and collateral review. The Court also held that the defendant's commuted sentence was the functional equivalent of a life without parole sentence, making it unconstitutional.

Summary

This 2013 case involved a juvenile offender tried as an adult, convicted of first-degree murder, and sentenced to life without parole. The defendant appealed for postconviction relief, leading to a commutation by the Governor to life without parole for sixty years. The District Court for Pottawattamie County deemed the Governor's commutation improper and resentenced the defendant to life with parole eligibility after twenty-five years, making him immediately eligible for parole. The State appealed the District Court's decision.

The Supreme Court of Iowa ruled that the Miller v. Alabama case, which found mandatory life-without-parole sentences for juveniles unconstitutional, applied retroactively to cases on direct and collateral review. The Court further ruled that the defendant's commuted sentence was functionally equivalent to life without parole, making it unconstitutional.

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Abstract

This 2013 case before the Supreme Court of Iowa involved a juvenile offender who was tried as an adult, convicted of first-degree murder, and sentenced to life without parole. The defendant appealed for postconviction relief and eventually the Governor commuted his sentence to life without the possibility of parole for sixty years. The District Court for Pottawattamie County said the Governor's commutation was improper and resentenced the defendant to life with the possibility of parole after twenty-five years, making him immediately eligible for parole. The State requested discretionary review. The Supreme Court of Iowa held that under Miller v. Alabama applied retroactively to cases on direct and collateral review. The Court also held that the defendant's commuted sentence was the functional equivalent of a life without parole sentence, making it unconstitutional.

Summary

This case, decided in 2013 by the Supreme Court of Iowa, involved a young person who was tried as an adult for murder. The defendant was found guilty and sentenced to life in prison without the possibility of parole. The defendant appealed this sentence, and the Governor eventually changed the sentence to life in prison without parole for sixty years. However, a lower court ruled that the Governor's change was not valid and reinstated the original sentence of life without parole. The State appealed this decision to the Supreme Court of Iowa.

The Supreme Court of Iowa agreed with the lower court, finding that the defendant's sentence was unconstitutional. The Court based its decision on a previous Supreme Court case, Miller v. Alabama, which ruled that sentences of life without parole for juveniles are unconstitutional. The Court also found that the Governor's change to the sentence was essentially the same as the original sentence, which was also deemed unconstitutional.

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Abstract

This 2013 case before the Supreme Court of Iowa involved a juvenile offender who was tried as an adult, convicted of first-degree murder, and sentenced to life without parole. The defendant appealed for postconviction relief and eventually the Governor commuted his sentence to life without the possibility of parole for sixty years. The District Court for Pottawattamie County said the Governor's commutation was improper and resentenced the defendant to life with the possibility of parole after twenty-five years, making him immediately eligible for parole. The State requested discretionary review. The Supreme Court of Iowa held that under Miller v. Alabama applied retroactively to cases on direct and collateral review. The Court also held that the defendant's commuted sentence was the functional equivalent of a life without parole sentence, making it unconstitutional.

Summary

This story is about a teenager who was accused of a very serious crime. He was tried as an adult and found guilty. The judge sentenced him to life in prison without the possibility of ever getting out.

Later, the Governor decided to change the sentence. He said the teenager could be released from prison after sixty years. However, a judge said the Governor couldn't do that, so he changed the sentence again. The teenager could now be released after twenty-five years.

The Supreme Court of Iowa said that the teenager's sentence should be reviewed again. They decided that the sentence was unfair because the teenager was a minor when the crime happened. The court said the teenager deserved a chance to get out of prison eventually.

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Footnotes and Citation

Cite

836 N.W.2d 107, 121-22 (Iowa 2013)

Highlights