To implement its substantive constitutional prohibition against mandatory life-without-parole sentences, the U.S. Supreme Court Miller decision requires courts to establish a procedure providing for an individualized sentencing hearing tailored to the unique attributes of juveniles when prosecuted as adults for homicide and facing a sentence of life without parole. While the U.S. Supreme Court Graham decision flatly prohibits the imposition of a life-without-parole sentence for a nonhomicide crime committed by a juvenile in order to afford the juvenile a meaningful opportunity to gain release in the future based on maturity and rehabilitation, Miller prohibits mandatory life-without-parole sentences for juveniles, but would seemingly permit life-without-parole sentences that are not mandated by statute if the sentencing court has the power to consider the attributes of youth in the mitigation of punishment.
Ragland was seventeen years old when he and two friends attacked another group of boys in a grocery store parking lot. Ragland instigated the fight by making aggressive comments, while the boys in the other group attempted to avoid a conflict. Ragland's friend swung a tire iron he was carrying and struck one of the boys in the other group in the head. The injured boy fell to the ground and subsequently died from the blow. Ragland was charged with first-degree murder for the boy's death and was prosecuted as an adult. Following a jury trial, he was found guilty of first-degree murder under the felony-murder doctrine. The district court then sentenced Ragland to a term of life in prison without parole. The sentence was mandatory under Iowa law. Now 44 years old, a post-relief action was filed with the Supreme Court of Iowa, where Ragland contended that his sentence of mandatory life sentence without parole violates the constitutional prohibition against cruel and unusual punishment.
Does a mandatory life sentence without parole violate the constitutional prohibition against cruel and unusual punishment?
Yes, in this particular case.
The court properly resentenced defendant to life in prison with the possibility of parole after 25 years, making defendant immediately eligible for parole, since the U.S. Supreme Court Miller decision applied retroactively, and the Miller decision applied to sentences that were the functional equivalent of life without parole.