Iowa Teen’s Life Sentence for Killings Struck Down

(CN) — An Iowa court improperly handed down a life sentence without parole to a killer who gunned down his grandparents at age 17, the state Supreme Court ruled.

Isaiah Sweet was 17 when he shot and killed the couple who had raised him since he was 4. Richard and Janet Sweet had been married for 30 years, and Richard was Isaiah's biological grandfather.

In his confession, Sweet said Richard and Janet "treated me like shit," and that Richard "constantly told me to just kill myself and fall off the earth."

Sweet said he shot Richard in the head from behind for making his life "a living hell." He shot Janet next and then regretted his actions, he said, adding that he kissed the victims and prayed for forgiveness.

A clinical psychologist testified that he found Sweet to have the emotional maturity of a 12- to 14-year-old and that Sweet's actions were not "well executed plan of a common criminal."

In 2014, the Delaware County District Court sentenced Sweet to life without parole, finding his crimes to be horrific, premeditated and showing a lack of humanity.

By this time, however, a trio of U.S. Supreme Court decisions had found carefully defined the Eighth Amendment case law for sentencing juveniles to death or life in prison.

The 2005 case Roper v. Simmons said juveniles cannot receive the death penalty "no matter how heinous the crime." Five years later, Graham v. Florida banned life without parole for juvenile offenders who commit nonhomicide offenses.

The 2012 case Miller v. Alabama went a step further, striking down mandatory life-sentencing schemes for juveniles.

Life sentences are still possible for juveniles under Miller, just not mandatory.

Earlier this year, the Supreme Court applied Miller retroactively with its holding in Montgomery v. Louisiana.

Sweet argued that his sentence violated the Iowa Constitution because of his age, immaturity and impetuousness, and because of his prospects for rehabilitation.

The Iowa Supreme Court overturned Sweet's sentence 4-3 on Friday, with the majority noting that nine other states "have abolished life-without-the-possibility-of-parole sentences for juveniles, thereby establishing a clear direction toward abolition of the life-in-prison death penalty for juveniles."

"We conclude that sentencing courts should not be required to make speculative up-front decisions on juvenile offenders' prospects for rehabilitation because they lack adequate predictive information supporting such a decision," Justice Brent Appel wrote for the court.

Chief Justice Mark Cady joined the lead opinion and penned his own concurring opinion.

"I agree the new statutory scheme adopted by our legislature for sentencing juvenile offenders convicted of first-degree murder to life without the possibility of parole violates the cruel and unusual punishment clause," Cady wrote.

The ruling inspired separate dissents by Justices Edward Mansfield and Justice Bruce Zager. Each dissenter joined the other's opinion, and Justice Thomas Waterman joined both opinions as well.

"The reality is that there remains a consensus in favor of continuing to make LWOP sentences available for juvenile murderers," Mansfield wrote. "This is exemplified by the actions of our elected representatives last year and by the similar actions of twenty-two other states that have enacted post-Miller legislation continuing LWOP as a sentencing option for juvenile homicide offenders."

Zager said he wrote "separately to voice my ongoing objection to this court's lack of confidence in our district court judges' ability to make difficult sentencing decisions in the area of juvenile sentencing involving life without parole."

Justice David Wiggins, one of the members of the majority, wrote a separate concurrence to tackle Mansfield's dissent.

"The dissent contends our decision today means the parole board will release every juvenile from prison at some point in the future," Wiggins wrote. "That contention is nothing more than fearmongering."

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