State of Iowa, Appellee v. Damion John Seats, Appellant

Summary

The court vacated Seats's juvenile life-without-parole sentence and remanded for a new individualized resentencing hearing. It held that juvenile homicide sentencing begins with a presumption favoring life with parole and requires consideration of youth-related mitigating circumstances, the offender's background, the offense circumstances, and prospects for rehabilitation, together with specific findings supporting any life-without-parole sentence. The court declined to decide whether the Iowa Constitution categorically prohibits life without parole for juvenile homicide offenders. Justice Hecht, concurring, would adopt a categorical state-constitutional ban, while Justice Mansfield, dissenting, would uphold discretionary life without parole and the sentence imposed here.