State v. MajorsAnnotate this Case
The Supreme Court affirmed the judgment of the district court imposing a seventeen and one-half year mandatory minimum prison term before parole eligibility on Defendant's second resentencing for attempted murder during a home invasion after considering the youth sentencing factors under State v. Roby, 897 N.W.2d 127 (Iowa 2017), holding that there was no error in the sentence and that counsel was not constitutionally ineffective.
Defendant was seventeen years old at the time of the crime and was since resentenced twice, once in 2014 and once in 2018, as caselaw on juvenile sentencing evolved. In this appeal from his latest resentencing, Defendant argued that the district court failed to follow the Supreme Court's 2017 mandate to apply Roby and that his counsel was constitutionally ineffective for failing to retain a defense expert on the youth sentencing factors. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in applying the Miller/Lyle/Roby factors and deciding to impose the mandatory minimum sentence; and (2) Defendant's defense counsel had no duty to present a defense expert to testify regarding the Roby factors where Defendant decided to forgo retaining a defense expert.