State of Iowa v. Willard Noble Chaiden Miller

Willard Miller appeals from the judgment of sentence for murder in the first degree following a guilty plea. At the time of the acts leading to the judgment, Mr. Miller was a juvenile. The district court imposed a life sentence with a mandatory minimum of 35 years of incarceration before he would be eligible for parole. Miller argues: (1) the district court abused its discretion in ordering a 35-year mandatory minimum because it did not proceed from the presumption against mandatory minimums for juvenile offenders, and improperly analyzed the relevant sentencing considerations; (2) a district court cannot impose a mandatory minimum on a juvenile without hearing expert testimony on the juvenile’s brain growth and its effects on his or her behavior; and (3) mandatory minimum terms of incarceration for juvenile offenders violates article I, section 17 of the Iowa Constitution.

Holding: A defendant convicted of first-degree murder as a juvenile appeals his sentence of life imprisonment with the possibility of parole after serving thirty-five years. Affirmed.