State v. Sweet, 879 N.W. 2d 811 (Iowa 2016) – In 2013, juvenile defendant (age 17 at time of crimes) was convicted by guilty plea of two counts of first-degree murder. In 2014, Sweet was given a sentencing hearing based on Miller and the Iowa Supreme Court cases of Null, Pearson, and Ragland. After conducting an extensive hearing, the court sentenced Sweet to life without parole, stressing that Sweet’s crimes were premeditated, the expert’s evaluation of Sweet’s possibility of rehabilitation was overly optimistic, and that Sweet was the rare juvenile where a sentence of life without parole was warranted. Sweet appealed his sentence, arguing that Iowa should adopt a categorical rule banning juvenile life without parole. On appeal, the Iowa Supreme Court noted that:
In reviewing the case law development, we believe, in the exercise of our independent judgment, that 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 . . . [A] 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 . . . . No structural or procedural approach, including a provision of a death-penalty-type legal defense, will cure this fundamental problem . . . here, in imposing a sanction akin to the death penalty in some respects, the trial court simply will not have adequate information and the risk of error is unacceptably high, even if we were to require an intensive, highly structured inquiry similar to that required by the ABA guidelines for the defense of death-penalty cases.
The court noted that the U.S. Supreme Court’s reasoning in Roper “foreshadowed the fallacy of the predictive enterprise later narrowly reserved in Miller.” Further, social science research suggests that the answer to whether a child can be rehabilitated comes “only with the benefit of time and completion of brain development.” Therefore, the court reasoned, it does not make sense to “empower sentencing courts to make final decisions on opportunities for parole before the juvenile offenders’ prospects for rehabilitation are reliably known.” There is plenty of time to make those determinations later. “Because of the difficulty of applying the individual Miller factors, the likelihood that the multifactor test can be consistently applied by our district courts is doubtful at best . . . We should not ask our district court judges to predict future prospects for maturation and rehabilitation when highly trained professionals say such predictions are impossible.” The court thus concluded: “In sum, we conclude that sentencing courts should not be required to make speculative up-front decisions on juvenile offenders’ prospects for rehabilitation because they lack adequate predictive information supporting such a decision. The parole board will be better able to discern whether the offender is irreparably corrupt after time has passed, after opportunities for maturation and rehabilitation have been provided, and after a record of success or failure in the rehabilitative process is available.” For these reasons, the court adopted a categorical rule that juvenile offenders may not be sentenced to life without parole under Article I, Section 17 of the Iowa Constitution. Vacated and remanded for resentencing.