article: On November 22, 2013, a man that had been in custody for twenty-five years for a crime committed when he was sixteen filed this lawsuit in the U.S. District Court for the Southern District of Iowa. The plaintiff sued the Iowa Board of Parole and the Iowa Department of Corrections (IDOC) under 42 U.S.C. § 1983. The plaintiff, represented by the University of Iowa Law School Clinic, asked the court for declaratory and injunctive relief, claiming that the parole board’s actions and policies violated his Eighth and Fourteenth Amendment rights. Specifically, the plaintiff claimed that he was being denied the opportunity for meaningful release while he was being detained under a mandatory adult life sentence for the crime he committed when he was sixteen. The plaintiff was not attempting to invalidate his life sentence, rather he was requesting a meaningful opportunity to obtain release based on his youth at the time the crime was committed combined with his demonstrated rehabilitation and maturity during the time he had already spent in prison. In <i>Graham v. Florida</i>, the Supreme Court stated that “Constitution prohibits the imposition of a life without parole sentence on a juvenile offender who did not commit homicide” and to sentence otherwise was cruel and unusual punishment prohibited by the Eighth Amendment 130 S.Ct. 2011, 2034 (2010). Under <i>Graham</i>, the State is required to give juvenile offenders who did not commit homicide a meaningful opportunity to obtain release. The plaintiff had previously filed a motion to correct his illegal sentence on October 15, 2010 in a separate lawsuit, filed in Iowa State Court. The motion was granted by Judge Carroll, who resentenced the plaintiff to life with eligibility for parole. The amended sentence established that the plaintiff was then eligible for parole as he had served past the statutory minimum of twenty-five years. The plaintiff applied for parole several times and was summarily denied based on the grounds of the seriousness of the offense he committed. No other grounds, such as the fact that he was an exemplary inmate for nearly thirty years and had only one minor infraction during that time, were considered during the parole review. In addition to the policies that failed to take into account the plaintiff’s youth at the time and demonstrated maturity over the course of imprisonment, the parole board also required that the plaintiff take sex offender courses due to the nature of his crime. The plaintiff attempted to enroll in these courses, but was denied because of the Department of Corrections’ enrollment policy. Under IDOC policy, an inmate was only eligible to take the course if there were within two years of their date of discharge. Since inmates serving a life sentence lack a date of discharge, they are permanently unable to enroll in the classes required by the parole board. As a result, the plaintiff claimed that the IDOC had failed to implement any policies that would give the plaintiff a meaningful opportunity to obtain release based on rehabilitation and demonstrated maturity. The defendants filed a motion to dismiss on February 7, 2014. On January 15, 2015, the court (Judge Robert Pratt) denied the defendant’s motion. The court found that the plaintiff did, in fact, state a plausible claim that the defendants violated his Eighth and Fourteenth Amendment rights by denying him a meaningful opportunity to obtain release, denying the motion in its entirety. 79 F.Supp.3d 933. The parties then engaged in discovery for more than two years. According to a status report filed on June 15, 2017, the plaintiff was granted work release status. On October 3, 2017, the parties filed stipulation of dismissal of all claims without prejudice, which the court granted the next day. No reasons were provided. The case is now closed.
summary: This case was filed on November 23, 2013 and alleges that the Iowa Department of Corrections violated an inmate’s right to due process and protection from cruel and unusual punishment by denying him a meaningful opportunity for parole. The inmate was a juvenile offender, but was sentenced to a mandatory adult life sentence without parole. The Supreme Court eventually deemed it unconstitutional to give juveniles life sentences without parole, so the plaintiff was resentenced to life with parole and was applying to be released based on demonstrated maturity and rehabilitation. The case is still ongoing.