Breeden v. Iowa Department of Corrections
Annotate this CaseShannon Breeden and Laura Hochmuth, both juveniles when their crimes were committed, were convicted of forcible felonies listed in Iowa Code 902.12. Both offenders were subject to the mandatory minimum requirement to serve at least seven-tenths of their sentences before becoming eligible for parole or work release. Each offender received a sentence with a mandatory minimum, and the Iowa Department of Corrections (IDOC) classified their sentences as category “B” for purposes of calculating earned-time credit. The Supreme Court subsequently decided State v. Lyle, which required resentencing of all offenders serving prison sentences with automatically imposed mandatory minimum terms for crimes committed as juveniles. The district court then resentenced Breeden and Hochmuth to an indeterminate term of years but without a mandatory minimum. The IDOC continued to classify the offenders’ sentences as category “B” such that their earned-time continued to accrue at a slower rate than the rate provided for under category “A.” The court of appeals reversed based on the plain language of section 903A.2(1), which provides that earned-time credit accrues at the faster rate for sentences lacking a mandatory minimum term. The Supreme Court affirmed, holding that removal of the mandatory minimum triggers the faster accrual for earned-time credit. Remanded.
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