Iowa criminal law, Miller v. Alabama

Iowa case law summary by Attorney Richard Clem: Iowa criminal law, Miller v. Alabama.

State of Iowa v. Andre Jerome Lyle Jr.. Iowa criminal law, Miller v. Alabama

State of Iowa v. Andre Jerome Lyle Jr. No. 11-1339 (Iowa July 18, 2014).

Andre Jerome Lyle Jr. was a 17 year old high school student in Des Moines. His father was in prison, his mother had threatened him with a knife, and he was being raised by his grandmother. He was frequently absent from school, and his grandmother permitted him to smoke marijuana. He had frequent contact with law enforcement and had an extensive juvenile record including assaults and robberies.

In 2010, he and a companion had paid $5 to another young man the day before for a small bag of marijuana. When the seller failed to deliver, the two punched the seller and took the marijuana. Conveniently for the prosecution, Lyle had videotaped the whole incident with his cell phone. He was convicted as an adult, and sentenced on his 18th birthday. He was given a mandatory sentence of ten years and was not eligible for parole for at least seven years. He objected to the mandatory minimum sentence as being cruel and unusual for a juvenile, and the case ultimately made its way to the Iowa Supreme Court.

While the appeal was pending, the U.S. Supreme Court decided Miller v. Alabama, 132 S. Ct. 2455, (2012), which addressed mandatory minimum sentence for crimes committed by juveniles.

In a long opinion by Chief Justice Cady, the high court held that article I, section 17 of the Iowa Constitution forbids a sentencing schema for juvenile offenders that deprives the district court the discretion to consider youth and its attendant circumstances as a mitigating factor and to impose a lighter punishment, including one that suspends all or part of the sentence, including any mandatory minimum. Accordingly, the court remanded for re-sentencing. In so holding, the court recognized that many cases will follow, since all prisoners sentenced to a mandatory minimum for crimes committed as juveniles will need to be re-sentenced. But it noted that this burden was one that the Iowa courts were obligated to assume.

Justices Waterman, Mansfield, and Zager dissented and would have affirmed the sentence.

For two recent Minnesota cases construing Miller v. Alabama, see Kim Thul Ouk v. State of Minnesota and Tony Allen Roman Nose v. State of Minnesota.

No. 11-1339 (Iowa July 18, 2014).

Please see the original opinion for the court's exact language.


Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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