State v. Pearson, 836 N.W.2d 88 (Iowa 2013) – (Direct appeal) – (State Constitutional Holding) – Juvenile defendant (age 17 at time of crimes) was convicted of two counts of first degree robbery and two counts of first degree burglary. She was sentenced to 50 years in prison, with parole eligibility after 35 years. The offenses carried mandatory minimum sentences, and the court had discretion to impose consecutive or concurrent sentences (it imposed consecutive sentences on some counts). The Iowa Supreme Court remanded for resentencing, concluding:
Here, the district court sentenced Pearson to consecutive terms totaling thirty-five years imprisonment without the possibility of parole. We think in light of the principles articulated in Miller and Null that it should be relatively rare or uncommon that a juvenile be sentenced to a lengthy prison term without the possibility of parole for offenses like those involved in this case. Otherwise, we would be ignoring the teaching of the Roper–Graham–Miller line of cases that juveniles have less culpability than adults, that the few youth who are irredeemable are difficult to identify, and that juveniles have rehabilitation potential exceeding that of adults.
[W]e think a minimum of thirty-five years without the possibility of parole for the crimes involved in this case violates the core teachings of Miller. . . the principles in Miller as developed by the Supreme Court in its Eighth Amendment jurisprudence are instructive on the resolution of this case. As in Null, we independently apply article I, section 17 of the Iowa Constitution, adopt the principles underlying Miller, and apply them to the facts of this case.
We have no occasion to consider whether Miller’s principles must be applied to all juvenile sentences. Instead, we need only decide that article I, section 17 requires an individualized sentencing hearing where, as here, a juvenile offender receives a minimum of thirty-five years imprisonment without the possibility of parole for these offenses and is effectively deprived of any chance of an earlier release and the possibility of leading a more normal adult life.
. . . .
In sum, the district court emphasized the nature of the crimes to the exclusion of the mitigating features of youth, which are required to be considered under Miller and Null. Accordingly, we vacate Pearson’s sentence and remand the case to the district court for application of the Miller standards as described in Null and this opinion.
(citations omitted; emphasis added). Vacated sentence and remanded to the district court for resentencing.