107 Iowa L. Rev. 1801 (2022)

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Abstract

In State v. Lyle, the Iowa Supreme Court ruled mandatory minimum sentences, without sentencing courts considering individualized factors, are unconstitutional punishments for juvenile criminal offenders. Although the Court correctly identified the unconstitutional nature of mandatory minimum sentences as punishments for juvenile criminal offenders, State v. Lyle resulted in a system of faulty individualized sentencing hearings that pose the same risk of cruel and unusual punishment the Court sought to prevent. This Note argues a categorical ban on mandatory minimum sentences for juvenile criminal offenders would resolve the shortcomings of State v. Lyle and prevent sentencing courts from subjecting juvenile criminal offenders to cruel and unusual punishments, while promoting rehabilitation. This Note further argues that a categorical ban is the best and most just solution to the problems persistent in Iowa’s post-Lyle sentencing system.