State v. Sweet

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

State v. Sweet follows a line of cases from the Iowa Supreme Court applying the Iowa Constitution to provide greater protections against excessive criminal punishments for youth than does the federal 8th Amendment. At 17 years old, Isaiah Sweet was sentenced to life without parole for killing his grandparents. Sweet’s sentence followed a “Miller hearing” in which the sentencing court found that he was the “rare juvenile” worthy of a life without parole sentence. On review, the Iowa Supreme Court held that no sentencing court can determine that a juvenile is “irretrievable,” and therefore youth life without parole is never an appropriate sentence.

Article I, Section 17 of the Iowa Constitution forbids sentencing youth to serve life without the possibility of parole.

The court began with Miller v. Alabama, the U.S. Supreme Court case that banned mandatory life without-parole sentences for youth under age 18. Miller, however, was not absolute—a youth could be sentenced to life without parole if the sentencing court found they are the “rare juvenile offender whose crime reflects irreparable corruption.” In Sweet, the Iowa Supreme Court used the state constitution to reject the possibility of such findings, and called the practice a “fallacy”:

“The enterprise of identifying which juvenile offenders are irretrievable at the time of trial is simply too speculative and likely impossible given what we now know about the timeline of brain development and related prospects for self-regulation and rehabilitation.” The court further explained that the “district court at the time of trial cannot apply the Miller factors in any principled way to identify with assurance those very few adolescent offenders that might later be proven to be irretrievably depraved. In short, we are asking the sentencer to do the impossible, namely, to determine whether the offender is ‘irretrievably corrupt’ at a time when even trained professionals with years of clinical experience would not attempt to make such a determination.”