100 Iowa L. Rev. 323 (2014)

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Abstract

In 2009, the Iowa Supreme Court decided State v. Bruegger, dramatically changing the court’s cruel and unusual punishment precedent under Article I, Section 17 of the Iowa Constitution. Prior to Bruegger, the court interpreted Article I, Section 17 in lockstep with federal Eighth Amendment interpretation, deeming the two provisions identical in scope, import, and purpose. However, Bruegger inexplicably altered this precedent by applying Article I, Section 17 more stringently than the Eighth Amendment. Defendants in Iowa began seeking heightened protection under the Iowa Constitution—protection Bruegger’s new interpretation seemingly afforded. When the Iowa Supreme Court decided State v. Null and State v. Pearson on August 16, 2013, and State v. Lyle on July 18, 2014, it solidified Bruegger’s standardless interpretation and again failed to enunciate a principled basis for interpreting Article I, Section 17 independent of the Eighth Amendment. These recent cases do not explain what in the Iowa Constitution justifies the new interpretation, or how the new interpretation will be applied to future cases. By evaluating the problems resulting from Null, Pearson, and Lyle, demonstrating several bases supporting adherence to federal interpretation, and suggesting alternative methods of interpretation, this Note demonstrates why the Iowa Supreme Court should reject Null, Pearson, and Lyle’s standardless interpretation and adopt a principled basis for independent interpretation of Article I, Section 17 in the future.