Ed. note: When we heard that Temple Law student Alex Dutton’s law review article on juvenile sentencing was cited in a landmark decision by the Iowa Supreme Court, we wanted to know more. So, we asked Alex to explain the issue he explored in his scholarship, the question before the Court, and the contribution he made to the outcome. Here’s what he had to say.
TL: What’s the problem that your scholarship addresses?
AD: In June 2012, the Supreme Court of the United States struck down mandatory life without parole sentences for juveniles convicted of homicide offenses. This ruling, announced by the Court in Miller v. Alabama, applied a fresh constitutional principle: that children, in light of neurological research explaining that the adolescent brain is undeveloped in critical areas that impact decision-making, are unique in terms of criminal sentencing. Specifically, children lack the decision-making capacities of adults, and thus, are categorically less culpable offenders, even when they commit violent crimes. Thus, the Court held that courts must consider mitigating circumstances, including the characteristics of youth, before sentencing a juvenile to life without parole. To do so, the Court applied a strand of constitutional law that requires individualized sentencing prior to the imposition of the death penalty. Across the country, many states employ mandatory minimum sentences to punish violent criminals. Mandatory minimums remove discretion from the sentencing judge to tailor a sentence that reflects the specific level of culpability displayed in a particular criminal instance. Mandatory minimums are common for drug- and gang-related violent crimes and range from year- to decades-long prison sentences. No matter their length, mandatory sentences strip judges of the ability to apply a more individualized sentence that would address the unique culpability of a youthful offender.
TL: What was the issue in the Iowa case?
AD: In State v. Lyle, the Supreme Court of Iowa struck down all mandatory minimum sentences applied to youth and ordered re-sentencing hearings for the approximately one-hundred young people currently serving mandatory prison terms in Iowa. In Lyle, the defendant was sentenced to a seven-year mandatory minimum sentence following his conviction for a schoolyard assault (over a five-dollar bag of marijuana). The defendant had a troubled childhood: his father was in prison and he was raised by his grandmother after his mother threatened him with a knife. However, because of the mandatory minimum that attached to the crime, the sentencing judge could not consider how the defendant’s childhood, life circumstances, and undeveloped decision-making skills influenced his behavior in this instance. Lyle challenged his sentence, arguing that Miller required the sentencing court to consider the attendant circumstances of youth before sentencing him. On appeal, the Supreme Court of Iowa reasoned that Miller’s principle that children are different for the purposes of sentencing applied not only to life terms of incarceration, but to any term of incarceration.
TL: How did the Court use your scholarship?
AD: The Supreme Court of Iowa cited my article for two general propositions, providing context for the growth of mandatory sentencing practices in the United States and the current state of the practice across jurisdictions. However, the opinion reflects my article’s general premise: that the reasoning in Miller applies to all mandatory sentences, not just life without parole. Needless to say, the decision is very progressive and happened sooner-let alone at all-than I anticipated.
Alex’s article, The Next Frontier of Juvenile Sentencing Reform: Enforcing Miller’s Individualized Sentencing Requirement Beyond the JLWOP Context, can be found at 23 Temp. Pol. & Civ. Rts. L.Rev. 173 (2013).