The Iowa Supreme Court ruled that juveniles convicted of first-degree murder may not be sentenced to life without parole. The court reasoned that sentencing a juvenile to life without parole was cruel and unusual punishment under the Eighth Amendment to the U.S. Constitution and emphasized that "sentencing courts should not be required to make speculative up-front decisions on juvenile offenders' prospects for rehabilitation."
According to Jurist, the court noted that it may be determined that an individual is beyond rehabilitation after time has passed, "after a record of success or failure in the rehabilitative process is available." The court also emphasized that parole was not guaranteed to juveniles, but rather only needs to be left available.
The court wrote: “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.”
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