Supreme Court of Iowa

State of Iowa, Appellant v. Jeffrey K. Ragland, Appellee

August 16, 20132013 Iowa Sup. LEXIS 93

Summary

The court held that the rule prohibiting mandatory life-without-parole sentences for juvenile homicide offenders applies retroactively on collateral review. It further held that Ragland's commuted sentence requiring sixty years before parole eligibility was the functional equivalent of life without parole and therefore still required individualized sentencing. The court affirmed the district court's resentencing after considering Ragland's youth and other mitigating circumstances. Justices Wiggins, Mansfield, and Zager concurred specially, addressing or disputing aspects of the Governor's commutation authority and the functional-equivalence analysis.