State of Iowa v. Andre Jerome Lyle Jr.

Summary

The court held that article I, section 17 of the Iowa Constitution categorically prohibits mandatory minimum imprisonment schemes for offenses committed by juveniles because they prevent sentencing courts from considering youth and its attendant circumstances as mitigating factors. The court vacated Lyle’s sentence and remanded for a hearing to determine whether the mandatory minimum was warranted after individualized consideration. Justices Zager and Waterman dissented, arguing that the sentence was neither grossly disproportionate nor subject to a categorical constitutional prohibition.