State v. Louisell
Annotate this CaseAfter a jury trial in 1988, Defendant was convicted of first-degree murder. Defendant was sentenced to life imprisonment without parole (LWOP), as required by Iowa law at that time. At the time she committed the crime, Defendant was seventeen years old. After Miller v. Alabama was decided, the Iowa Governor commuted Defendant’s LWOP sentence, along with the sentences of several other juvenile offenders, to life imprisonment with the possibility of parole after sixty years in prison. After the Iowa Supreme Court decided State v. Ragland, the Court summarily vacated Defendant’s sentence and remanded the case for an individualized sentencing hearing. After a hearing, the district court resentenced Defendant to a definite term of twenty-five years with credit for time served, thereby discharging her from prison immediately and releasing her to correctional supervision for no more than two years. The court also imposed an alternative sentence of life in prison with the possibility of parole after twenty-five years. The Supreme Court vacated the sentence, holding that the district court (1) lacked authority to impose a determinate sentence of twenty-five years, but (2) did have authority to impose a sentence of life in prison with eligibility for parole.
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