State v. Pearson

IOWA CONST. art. 1, § 17 (“cruel and unusual punishment”)

Pearson was 17 years old when she was convicted of first-degree robbery and first-degree burglary. Both convictions carried with them a 25-year sentence which Pearson was ordered to serve consecutively. Before Pearson could be eligible for release, she would have had to serve at least 70% of her sentence—35 years. As in State v. Null, also decided in 2013, this case challenged a term-of-years sentence given to a youth under 18 as an unconstitutional de facto life without parole sentence.

Requiring youth to serve 35 years in prison before the possibility of release is a de facto life without parole sentence, and sentencing courts must consider the “mitigating features of youth” and the goal of rehabilitation before imposing such lengthy sentences.

The court reversed Pearson’s sentence and remanded it with instruction to follow their holding in State v. Null. In Null, the court explained that juveniles are constitutionally different from adults. Relying on a string of U.S. Supreme Court cases, the court identified juveniles as generally lacking maturity, possessing an underdeveloped sense of responsibility, being vulnerable to peer pressure, having a less fixed nature of their character, and being more capable of rehabilitation than adults. The Null court instructed that these “features of youth” are to be treated as mitigating factors that must be considered during sentencing.

Here, the court noted that the district court had explicitly chosen not to regard Pearson’s age as a mitigating factor during sentencing. “[T]he district court indicated it understood the argument that Pearson, as a young person, may lack the ability to appreciate the results of her actions, but then stated that argument doesn’t diminish in any way the results of her actions.” However, as discussed in the U.S. Supreme Court decision Miller v. Alabama, and in the Iowa Supreme Court decision State v. Null, a juvenile’s inability to fully comprehend their actions and the consequences of those actions lessen the juvenile’s culpability and must be treated as a mitigating factor.

Moreover, the district court did not focus on Pearson’s potential for rehabilitation when imposing its sentence. The court explained that although predicting the potential of rehabilitation is very difficult, it should consider the goal of rehabilitation in Pearson’s case. Because Pearson was sentenced without having her age and the goal of rehabilitation fully taken into account the court reversed and remanded her sentencing.