State of Iowa, Appellee v. Denem Anthony Null, Appellant

Summary

The court affirmed Null’s convictions and rejected his ineffective-assistance challenges concerning the plea colloquy and withdrawal of his juvenile-transfer motion. It held that the Iowa Constitution requires individualized consideration of youth before imposing a lengthy term-of-years sentence that requires a juvenile to serve 52.5 years before parole eligibility, and it vacated the sentence for resentencing. On remand, the district court must consider the distinctive characteristics of youth, the possibility of rehabilitation, and whether consecutive sentences would produce an unconstitutional prison term. Justice Mansfield, joined by Justice Waterman, and Justice Zager concurred in affirming the convictions but would have affirmed the sentence or, alternatively, ordered only a straightforward remand under the federal rule.