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State of Iowa v. Noah Riley Crooks
Citation: 911 N.W.2d 153Docket: 16-0851
Court: Supreme Court of Iowa; April 20, 2018; Iowa; State Supreme Court
Original Court Document: View Document
Noah Riley Crooks, convicted of second-degree murder at age thirteen for fatally shooting his mother, appealed his fifty-year prison sentence imposed at age eighteen. The Iowa Supreme Court affirmed the conviction and sentence, addressing Crooks' statutory and constitutional challenges to his prosecution in adult court. He contended that his case should have remained in juvenile court and argued for probation or placement in a transitional facility instead of prison. The court found that the district court exercised proper discretion based on an individualized assessment of Crooks under the constitutional statutory framework. The background reveals that on March 24, 2012, Crooks shot his mother twenty-two times, later expressing regret and concern about his future, including the impact of his crime on his aspirations. The court acknowledged ongoing national sentencing reform efforts but emphasized that such changes should be pursued through legislative action rather than judicial intervention. Deputy Jeff Huftalin responded to a call at the Crooks residence, where he discovered Gretchen deceased on the couch with bullet wounds, while her son Noah, age thirteen, indicated the presence of a gun. Deputy Huftalin handcuffed Noah and informed William, Gretchen's partner, of the incident, stating that Noah had shot her. Four days later, the State filed a delinquency petition against Noah for first-degree murder and assault with intent to commit sexual abuse, requesting the juvenile court to waive jurisdiction to allow prosecution as a youthful offender under Iowa Code section 232.45(7) (2011). Noah challenged this waiver, first questioning the juvenile court's authority over a thirteen-year-old and later asserting the constitutionality of the youthful offender statute, both of which the court denied. The juvenile court found sufficient grounds for waiver, confirming Noah was under fifteen, probable cause existed for the alleged felonies, and there were no rehabilitation prospects before his eighteenth birthday. Consequently, the case was transferred to district court, where Noah faced charges of murder and assault. He asserted defenses of insanity and diminished responsibility, resulting in a conviction for second-degree murder and acquittal on the assault charge. Noah was designated a youthful offender, with supervision transferred to juvenile court, which later placed him in the State Training School in Eldora. Under juvenile court supervision, Noah participated in school and mental health treatment, graduating high school in May 2015. In April 2016, the juvenile court officer filed a report highlighting Noah's avoidance of discussing his mother's murder. During therapy, he expressed a lack of understanding of the consequences of his actions, indicating he thought life would improve without her and that he believed he would face minimal repercussions. A presentence investigation (PSI) was ordered by the district court, which recommended incarceration for the defendant, who shot and killed his mother at the age of 13 and will turn 18 on July 29, 2016. The PSI highlighted the defendant’s lack of prior criminal history, his involvement in family counseling, and a history of being prescribed psychotropic medication. Disturbing behaviors were noted, including comments about killing his mother, bullying peers, cruelty to animals, and potential arson at age 5–6. Despite claiming to have come from a good family and to have been close to his mother, he admitted to being "arrogant and stuck up" and showed no clear reasoning for his actions. At the State Training School, he exhibited generally acceptable behavior with minor violations, graduated from high school, and aspired to attend college. However, concerns about public safety and his potential future behavior were raised, with the PSI recommending higher supervision upon release. The proposed sentence was 45 years in custody. During a hearing on May 6, the State sought a 50-year indeterminate sentence, while the defense attorney argued for options limited to continuation of youthful offender status or discharge. The defense claimed any confinement or probation should not exceed five years, with credit for time served, and did not request placement in a transitional facility. The defendant expressed regret in a written statement and several family members provided victim-impact statements. The victim's brother requested the maximum sentence for the defendant, emphasizing a lack of empathy. The defendant's father expressed frustration over his son's indifference regarding the victim's death, asserting that four years was insufficient punishment for his mother's loss. The court observed a significant absence of emotional response, remorse, and empathy from the defendant, Noah, throughout the proceedings. While acknowledging Noah's youth and potential emotional immaturity, the court concluded that he had not adequately confronted his actions or demonstrated meaningful rehabilitation. The court noted recent signs of remorse but questioned their sincerity due to their timing. Concerns arose from Noah's dismissive comments about needing future services and his reluctance to engage with the rehabilitation process. The judge emphasized the necessity for further time to ensure Noah genuinely understands the implications of his actions and can demonstrate a commitment to change before considering probation. Consequently, the court found that incarceration was warranted and sentenced Noah to an indeterminate term of up to fifty years for second-degree murder, making him eligible for parole without a mandatory minimum sentence. Crooks appealed, contesting his classification as a youthful offender under Iowa Code section 232.45(7)(a) (2011), asserting that the statute lacks authority for trying a thirteen-year-old as such. He also argues that sections 232.45(7) and 907.3A infringe upon the Iowa Constitution's article I, section 17, which prohibits cruel and unusual punishment. Additionally, he claims the sentencing court abused its discretion in incarcerating him. The appeal was retained for review. The standard of review involves correcting errors of law for statutory interpretations, conducting de novo reviews for constitutional challenges, and assessing potential abuses of discretion in sentencing. The analysis begins with a review of the youthful offender statutes established in 1997 as part of juvenile justice reform. Typically, juvenile courts have exclusive original jurisdiction in delinquency cases but can transfer cases to adult court. A motion to waive jurisdiction can be filed either by the county attorney or the child before an adjudicatory hearing. Iowa Code section 232.45(7)(a) outlines the findings necessary for the juvenile court to waive jurisdiction for prosecution as a youthful offender. The court may do so if: 1) the child is fifteen years old or younger; 2) there is probable cause to believe the child committed a delinquent act constituting a public offense; and 3) the state demonstrates insufficient prospects for the child's rehabilitation before their eighteenth birthday. The court concluded that it was statutorily authorized to waive jurisdiction and determined that the waiver provisions do not constitute punishment, rejecting Crooks' claim regarding cruel and unusual punishment and declining to prevent prosecutions of thirteen-year-olds as youthful offenders. The juvenile court can waive jurisdiction for a child aged fourteen or older for adult prosecution, but amendments in 2013 allow for the waiver for children aged twelve to fifteen, or for children aged ten or eleven charged with a class 'A' felony. Crooks contends that Iowa Code section 232.45(7)(a) does not permit waiving jurisdiction over thirteen-year-olds for youthful offender prosecution, arguing the language creates ambiguity. However, it is concluded that the statutes clearly allow for prosecution of thirteen-year-olds as youthful offenders. The distinction in language between the adult prosecution waiver and the youthful offender waiver illustrates legislative intent, as the legislature has demonstrated the ability to set age limits distinctly. Therefore, Crooks, who was thirteen at the time of the offense, can be prosecuted as a youthful offender. Crooks also challenges the constitutionality of Iowa Code sections 232.45(7)(a) and 907.3A under the Iowa Constitution's prohibition on cruel and unusual punishment. The court emphasizes that statutes are presumed constitutional, placing the burden on the challenger to prove unconstitutionality beyond a reasonable doubt. If a statute can be interpreted in multiple ways, one of which is constitutional, that interpretation must be adopted. The court will first consider Crooks's assertion that the waiver to district court constitutes cruel and unusual punishment, followed by his challenge to the fifty-year sentence imposed under section 907.3A. The waiver process outlined in section 232.45(7) does not constitute punishment, as argued by Crooks. The waiver transfers a child from the rehabilitative juvenile system to the adult system, which emphasizes incapacitation, retribution, and deterrence. Iowa's juvenile justice system prioritizes rehabilitation, with the Supreme Court recognizing four legitimate penological justifications: retribution, deterrence, incapacitation, and rehabilitation. For a waiver to occur, the juvenile court must determine that there are no reasonable prospects for rehabilitation before the child's eighteenth birthday. Following the jurisdiction transfer, if the youthful offender pleads guilty or is found guilty, the district court will defer sentencing and supervise the offender under the juvenile system until close to their eighteenth birthday. A hearing will then assess whether to maintain youthful offender status or discharge the individual, considering available services, evidence, and the interests of both the offender and the community. Ultimately, the waiver does not immediately subject the child to adult sanctions, allowing for continued rehabilitation efforts before determining future action. The court must make specific findings throughout the process and has discretion regarding the outcome, including when the child turns eighteen. The waiver process for transferring juveniles to adult court is not deemed punishment under article I, section 17 of the Iowa Constitution. Various jurisdictions have similarly ruled that waiver statutes do not constitute punishment for constitutional purposes. For example, in State v. Jensen (Idaho) and People v. Patterson (Illinois), the courts concluded that waivers do not impose punishment under the Eighth Amendment or related state provisions. The State v. Mays (Ohio) and State v. Rodriguez (Arizona) decisions further reinforce that transfer statutes do not enhance punishment but simply move juveniles into the adult criminal justice system. Crooks did not provide any cases to substantiate his claim that waiver statutes amount to punishment. He references cases like R.H. v. State (Alaska), which discusses the procedural implications of juvenile waivers but does not assert that being tried as an adult constitutes cruel and unusual punishment. Similarly, in Ramona R. v. Superior Court (California), the court held that statements made during a fitness hearing cannot be used against a minor at trial without addressing the issue of cruel and unusual punishment. Crooks also cites a dissent in People v. Hana (Michigan), which acknowledges the punitive nature of waiving juvenile jurisdiction but does not link this view to a claim of cruel and unusual punishment, as the majority opinion clarified that Fifth and Sixth Amendment protections do not apply in these waiver hearings. In the discussed cases, children tried as adults face severe penalties, including life imprisonment or lengthy mandatory minimum sentences, contrasting sharply with Crooks, who was tried as a youthful offender and received a sentence with immediate parole eligibility and no mandatory minimum. The court determined that Iowa’s waiver provision for youthful offenders does not constitute cruel and unusual punishment under article I, section 17 of the Iowa Constitution. Crooks argues that sentencing a thirteen-year-old as a youthful offender violates this constitutional provision and calls for a categorical prohibition against adult court sentencing for children under fourteen. The analysis references U.S. Supreme Court precedents, including Roper, Graham, and Miller, which collectively establish that juveniles should not face the death penalty or life without parole for nonhomicide offenses, and that mandatory life sentences for juveniles are unconstitutional. Iowa courts have extended these principles, emphasizing the need for individualized sentencing hearings before imposing lengthy minimum sentences on juvenile offenders. Previous Iowa rulings have deemed automatic mandatory minimum sentences for juveniles unconstitutional and require consideration of Miller factors in sentencing. Crooks requests the court to define the age at which a child may face adult prosecution, prompting the court to deliberate on the broader implications of adopting such a categorical rule regarding juvenile punishment under the cruel and unusual punishment clause. The legal framework acknowledges the complexities of juvenile behavior and the potential for rehabilitation while balancing the need to protect society from serious offenses. Sentencing decisions must consider individual circumstances, particularly in violent crime cases. The court upheld the sentence imposed on Crooks, asserting that it did not abuse its discretion and that Crooks' constitutional rights were not violated in applying youthful offender statutes. The previous statute mandated a minimum twenty-five-year sentence for juveniles convicted of class “A” felonies (excluding first-degree murder) and prohibited parole for first-degree murder convictions. The amended statute allows for new sentencing options for juveniles convicted of first-degree murder, including life without parole or life with the possibility of parole after a minimum term or with no minimum confinement. The 2015 legislative changes eliminated life without parole for juvenile offenders, as established in Sweet v. State. The Iowa Supreme Court, in State v. Zarate, rejected a facial challenge to the amended provisions of section 902.1(2), applying a two-step approach for assessing cruel and unusual punishment under the Iowa Constitution. This involves evaluating any consensus on the issue and making an independent judgment based on precedents and the Iowa Constitution's principles. The court emphasized the importance of considering the offenders' culpability relative to their crimes and the severity of the punishment, while also granting substantial deference to the legislature in determining penalties for crimes. The United States Supreme Court has emphasized that state legislation serves as the clearest evidence of contemporary societal values, particularly in the context of the Eighth Amendment's prohibition against cruel and unusual punishment. Chief Justice Roberts underscored the importance of state legislative judgments in shaping this constitutional standard, noting that legislatures reflect community standards more reliably than courts. The document points out that the trend in juvenile sentencing is moving away from mandatory penalties, allowing for greater discretion in court decisions regarding juvenile offenders, which indicates a growing consensus to treat juveniles differently than adults in the justice system. Iowa's laws require specific factual findings for individualized sentencing of youthful offenders, further signifying the necessity of legislative guidance in these matters. Consequently, the document supports the Iowa legislature's authority to allow the prosecution of thirteen-year-old defendants as youthful offenders in district court, contingent upon appropriate judicial findings. Twenty-one states allow children under fourteen to be prosecuted as adults, with varying age thresholds for specific offenses. Notably, some states have no minimum age limit for certain prosecutions, while others set the minimum age at twelve or thirteen, depending on the offense. For instance, states like Alaska and Maine impose no lower age limit, while Georgia and Mississippi establish thirteen as the age for exclusive adult jurisdiction for specific crimes. Crooks points out the lack of consensus on the minimum age for criminal responsibility but emphasizes that this lack of agreement does not determine the legal standards. He references a study by Jeree Thomas from the Campaign for Youth Justice, which discusses legislative reforms aimed at keeping youth out of adult courts. No judicial decisions have invalidated laws permitting the transfer of youthful offenders to adult court. The report advocates for state legislatures to raise the minimum age for adult prosecution, noting that four states have already enacted laws to prevent the automatic prosecution of 16- and 17-year-olds as adults. It also calls for the restoration of judicial discretion in waiver and transfer decisions, which many states currently lack; Iowa's youthful offender laws already provide for such discretion. The document expresses agreement with the Campaign for Youth Justice (CFYJ) that policy arguments for juvenile sentencing reform should be directed to the legislature. It asserts an independent judgment, rejecting a categorical bar requested by Crooks, as individualized protections for youthful offenders align with existing legal precedents. The juvenile court is required to hold an individualized hearing, considering specific factors before waiving jurisdiction to allow prosecution as a youthful offender. Upon a guilty finding, the district court must transfer supervision back to juvenile court for disposition, which mandates the least restrictive dispositional order. Before the youthful offender’s eighteenth birthday, the district court conducts another individualized hearing to determine one of four sentencing options: discharge from jurisdiction, continuation of a deferred sentence, imposition of a suspended sentence with probation, or an indeterminate sentence. These individualized hearings comply with constitutional protections established in prior rulings. The Supreme Court in Miller emphasized that discretion at the transfer stage does not replace the need for discretion at post-trial sentencing, as transfer decisions often lack complete information about the offender and the circumstances of the offense, and they typically present a stark choice between juvenile and adult sentencing outcomes. Discretionary sentencing in adult court allows judges or juries to opt for alternatives to life without parole, such as a lifetime prison term with parole eligibility or lengthy prison sentences. The Iowa youthful offender statutes meet the requirements set by Miller v. Alabama, offering individualized posttrial sentencing. These statutes mandate that youthful offenders be transferred back to juvenile court until age eighteen, providing an opportunity to assess their rehabilitation for nearly five years before sentencing. Crooks challenged the district court's discretion in imposing a maximum 50-year indeterminate sentence, arguing that the court overlooked other sentencing options, failed to apply relevant Miller factors, and improperly chose incarceration. Each claim was addressed: the court was found to have recognized multiple sentencing options and justified its decision for incarceration, emphasizing concerns about public safety and the offender's readiness for freedom. Crooks did not demonstrate that the court abused its discretion, as the record indicated the court was aware of and considered all available options, including discharge and probation. The court is not required to explain its rejection of specific options but must articulate reasons for the selected sentence, which it did in this case. The court expressed concerns regarding the defendant's emotional response and empathy, stating that the absence of these qualities raises doubts about the defendant's care for the situation and the likelihood of reoffending. Consequently, the court deemed it inappropriate to release the defendant on probation at this time and decided that incarceration was necessary, affirming the imposition of a sentence and conviction. The court's decision did not constitute an abuse of discretion, as it had considered available sentencing options. The defendant, Crooks, claimed that the district court failed to consider the Miller factors, which are necessary for sentencing juveniles as adults under certain circumstances. The relevant factors include the offender's age, family environment, the specifics of the crime, challenges faced by youth in the criminal justice system, and the potential for rehabilitation. The Miller ruling prohibits mandatory life sentences without parole for offenders under eighteen, and the court must evaluate these factors when imposing a minimum sentence. Additionally, prior cases established that a district court must assess the Miller/Lyle factors before applying mandatory minimum sentences for juvenile offenders. Crooks contended that since a minimum period of incarceration was available, the court was required to consider the Miller/Lyle factors on record. However, the State argued that such consideration is only necessary if a mandatory minimum sentence is being contemplated. The court referenced previous cases to clarify the limits of the Miller individualized sentencing requirement for juveniles not facing mandatory minimums. An indeterminate sentence for juveniles facilitates immediate eligibility for parole, allowing them to demonstrate rehabilitation and understanding of their actions to the parole board. If a juvenile has not rehabilitated, the board may choose to prolong incarceration until they show maturity and comprehension of their crime's severity. This aligns with previous rulings on juvenile sentencing, which emphasize a meaningful opportunity for parole based on demonstrated reform. The court clarified that constitutional protections do not target mandatory incarceration but rather the absence of opportunities for rehabilitation during incarceration. When sentencing a juvenile, there is no mandatory minimum imposed, and the sentence is framed as an indeterminate term, with the Board of Parole deciding on release. The court noted that no hearing on Miller/Lyle factors is necessary for sentencing with immediate parole eligibility, but mitigating circumstances related to youth must still be considered, including applicable Miller/Lyle factors. Aggravating factors must not overshadow the mitigating factors associated with youth. While the court is not required to explicitly address each Miller/Lyle factor on the record, all relevant factors must be considered in determining the appropriate sentence. An abuse of discretion may be found if a relevant factor is overlooked. The sentencing court considered multiple factors, including the Miller/Lyle criteria, and did not abuse its discretion in imposing a sentence of incarceration on Crooks. Crooks contended that the court wrongfully believed he was not rehabilitated and posed a danger to society, but the evidence supported the court's conclusion. The court evaluated the available services for youthful offenders, evidence presented, the juvenile court’s report, and the interests of both Crooks and the community, as mandated by Iowa Code 907.3A(2). The appellate court's role is to assess whether the district court's decision was unreasonable or based on untenable grounds, not to reevaluate the decision itself. Dr. Michael Taylor's 2012 evaluation indicated that Crooks had no prospects for rehabilitation and lacked remorse or guilt, attributing his actions to ingrained personality traits. Dr. Augspurger's evaluations in 2013 and 2016 found no diagnosable mental disorder but noted the uncertainty in predicting Crooks' future behavior. The district court’s decision to impose an indeterminate sentence of up to fifty years, with eligibility for parole, was within its discretion. Consequently, the judgment of conviction and sentence was affirmed. All justices concur except Appel, Wiggins, and Hecht, JJ., who partially concur and dissent. Justice Appel agrees with some aspects of the majority's decision but advocates for vacating the district court's ruling and remanding the case to consider the Lyle factors before convicting and sentencing Crooks, citing relevant case law, including State v. Lyle and Miller v. Alabama. Regarding statutory interpretation, Appel concurs with the majority that Iowa Code section 232.45 does not impose a minimum age for treating a child as a youthful offender. The statute provides two paths for juvenile transfer: one for children fourteen and older to be tried as adults, and another for those fifteen and younger to be treated as youthful offenders. Appel emphasizes caution in reading into statutes without compelling reasons, referencing prior Iowa case law. Appel also discusses the constitutional implications of trying thirteen-year-olds as youthful offenders. He notes scholarly critiques of juvenile transfers to adult court, suggesting that juvenile offenders should not be integrated with adults and should not face incarceration past age twenty-five. The absence of an age floor in the transfer statute is seen as problematic, as it raises concerns about the criminal culpability of very young children under the cruel and unusual punishment clause of the Iowa Constitution. The statute allows for case-by-case evaluations regarding criminal sanctions for thirteen-year-olds but Appel argues that such evaluations can be arbitrary, advocating for a categorical rule instead. He cites State v. Sweet, where a categorical prohibition against life without parole for juvenile offenders was established due to the unpredictability of assessing juvenile behavior. This underscores the need for reliable and accurate standards when determining consequences for young offenders. The central issue in this case is whether a district court can reliably identify which thirteen-year-old offenders are unlikely to be rehabilitated by age eighteen. Unlike the precedent set in Sweet, the current statute requires a less complex prediction regarding the need for short-term rehabilitative services rather than a long-term assessment of incorrigibility. While experts agree on the difficulty of making accurate long-term predictions for juveniles, there is no consensus that short-term assessments are equally unreliable. The statute includes a look-back provision, allowing for reassessment of a child's status as a youthful offender, thus mitigating the risk of arbitrary incarceration by ensuring that the child remains under juvenile authority rather than being subjected to adult punitive measures. This approach avoids automatic transfers to adult court, which could violate constitutional standards set by Miller and Lyle due to the lack of individualized determinations. Furthermore, the consequences of being labeled a youthful offender are less severe compared to Sweet, as it does not result in mandatory life sentences without the possibility of demonstrating rehabilitation. The ruling in Lyle also prevents the imposition of mandatory minimum sentences on children, reducing the risk of arbitrary penalties. However, concerns remain regarding the potential lack of adequate rehabilitation resources for incarcerated youth, which may hinder their chances for reform and carry constitutional implications. Access to rehabilitative programs for juvenile offenders is crucial for ensuring meaningful opportunities for release, as highlighted in legal literature. Education and treatment programs are essential to meet the requirements set forth in Graham v. Florida, which mandates a meaningful opportunity for rehabilitation. A correctional environment that fosters healthy psychological development is necessary for true reform, indicating a fact-based challenge to the conditions of incarceration rather than a categorical challenge to Iowa's transfer statute. While the statute's constitutionality is not deemed categorically invalid, especially concerning thirteen-year-olds, there are concerns regarding its application close to constitutional limits. The preferred approach is to allow for as-applied challenges rather than outright dismissal of the statute, especially if its application proves to be arbitrary or inconsistent in practice. The excerpt also addresses potential challenges to district court sentencing, particularly the court's awareness of its discretion under the applicable statute. If the district court fails to recognize its discretion, a remand for resentencing would be necessary. The defendant bears the burden of demonstrating this lack of awareness. The statute provides various sentencing options for youthful offenders, including deferred sentences and probation. If the district court imposes a sentence of confinement, credit must be given for any time previously spent in secure confinement. During the sentencing hearing, the district court indicated a belief that the options were limited to incarceration or probation. The district court identified two sentencing options: "street probation" and incarceration, expressing that the statute was poorly drafted. It asserted that there were no other options available based on its interpretation, despite the statute allowing for deferring or suspending the sentence with probation, which could include varying levels of supervision and placement in community-based or residential treatment facilities. The court's statements indicated a belief that it had only two stark choices and did not acknowledge the broader corrections continuum available under Iowa Code section 901B.1. Consequently, the court did not exercise its discretion properly, warranting a remand for resentencing. Additionally, the court must consider mitigating factors in sentencing, particularly recognizing that children are constitutionally different from adults, as established in case law. Factors such as underdeveloped responsibility, susceptibility to peer pressure, and the transient nature of juvenile character must be taken into account, as highlighted by several precedents. The constitutionally significant distinction between adults and children applies to all crimes, affirming that children are fundamentally different from adults in their capacity for culpability. This principle has broad implications, extending beyond severe sanctions to all contexts of juvenile sentencing in adult courts. Recognized authorities advocate for this developmental principle's application, emphasizing that mitigating factors associated with youth should be considered in discretionary sentencing, not just minimum sentences. The courts have consistently applied this principle in various contexts, including aggregate sentencing, mandatory minimums, and life sentences without parole. There is an ongoing discussion regarding the necessity for district courts to make explicit findings on the mitigating factors of youth during sentencing. Previous cases have established that simply acknowledging age is insufficient; specific considerations must be made, including the youth's chronological age, maturity levels, family environment, circumstances of the offense, and the potential for rehabilitation. These factors must be comprehensively analyzed to ensure a proportional and just sentencing framework for juvenile offenders. Crooks contended that his fifty-year prison sentence violated common law principles regarding the intent of young children and contradicted contemporary scholarly views on juvenile punishment, which were referenced by the Iowa Supreme Court in cases addressing cruel and unusual punishment for juveniles. He cited *Graham v. Florida*, emphasizing the characteristics of youth—immaturity, social development, risk assessment capabilities, and vulnerability to peer and familial pressures—as relevant factors in sentencing. The excerpt elaborates on the necessity of specific findings on mitigating factors related to youth in the context of sentencing, asserting that these factors should be treated as mitigating rather than aggravating, and should not be overshadowed by the severity of the crimes. While acknowledging differences in the context of this case compared to typical minimum sentencing scenarios, it argues for the importance of requiring district courts to articulate how the characteristics of youth influenced their sentencing decisions. The excerpt underscores that, unlike adult minimum sentences, the imposed sentence allows for the possibility of parole, indicating a less rigid framework. Nevertheless, the consequences of the sentence remain significant, warranting careful consideration. It concludes by advocating for the vacating of the district court's sentence and remanding for further proceedings, emphasizing the need for clarity in how youth-related factors were evaluated during sentencing. Judges Wiggins and Hecht concurred in part and dissented in part.