Description: Brandy Coleman appeals the district court’s denial of her postconviction
relief (PCR) application. She contends the district court erred in denying her
application because the indeterminate fifty-year prison sentence entered upon
her conviction amounts to cruel and unusual punishment in violation of the United
States and Iowa Constitutions.1
In 1996, a jury found Coleman guilty of possession of crack cocaine with
intent to deliver while in possession of a firearm—the district court sentenced her
to a term of imprisonment not to exceed fifty years but waived the mandatory
minimum sentence.2 See Iowa Code §§ 124.401(1)(b)(3), (e); 902.7; 902.9(1)
(1995). She was seventeen years old at the time of sentencing.
Coleman served approximately three years and nine months of her
sentence before she was granted parole. Her parole was subsequently revoked,
twice, as a result of four felony drug convictions and at least one assault
conviction. In November 2014, Coleman filed a PCR application requesting relief
on a number of grounds. She subsequently amended her application to include
a specific argument that her sentence was unconstitutional as cruel and unusual
1 Coleman also argues her sentence violates Equal Protection, contending it renders her similarly situated to youthful offenders who are subjected to mandatory minimum terms of imprisonment. This argument was not raised below, and we therefore do not consider it on appeal. See Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002) (“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.”). 2 Coleman was also convicted of a tax-stamp violation. On that count, the district court sentenced her to imprisonment for a period not to exceed five years, to run concurrently with the sentence imposed on the possession charge.
In its ruling, the district court recognized the sole legal issue was whether
Coleman’s fifty-year, indeterminate prison sentence with no mandatory minimum
is a violation of State v. Lyle, 854 N.W.2d 378, 382 (Iowa 2014), and its progeny.
The court concluded Coleman’s sentence was not in violation of precedent and,
therefore, denied Coleman’s PCR application. This appeal followed.
An unconstitutional sentence is an illegal sentence and may be corrected
at any time. Lyle, 854 N.W.2d at 382. “Although challenges to illegal sentences
are ordinarily reviewed for correction of legal errors, we review an allegedly
unconstitutional sentence de novo.” Id.
Coleman primarily relies on Lyle, which stands for the proposition that “all
mandatory minimum sentences of imprisonment for youthful offenders are
unconstitutional under the cruel and unusual punishment clause in article I,
section 17 of our constitution.” Id. at 400. Coleman concedes she was not
sentenced to a mandatory minimum term of imprisonment but argues she was
subjected to a “really long” prison sentence that amounts to cruel and unusual
punishment because she was a juvenile at the time of her criminal act.
One of Lyle’s specific teachings is that “juveniles can still be sentenced to
long terms of imprisonment, but not mandatorily.” Id. at 401. It is the mandatory
nature of the punishment that offends constitutional protections, not the length of
the sentence. Id. (discussing Miller v. Alabama, 567 U.S. 460 (2012)). Simply
stated, the constitution “does not prohibit judges from sentencing juveniles to
prison for the length of time identified by the legislature for the crime committed,”
it “only prohibits . . . mandatory sentences for juveniles.” Id. at 403. The Iowa
Supreme Court recently declined to expand Lyle to cases in which a youthful
offender “has no mandatory minimum period of incarceration and . . . is
immediately eligible for parole.” State v. Propps, 897 N.W.2d 91, 101 (Iowa
2017). Further, the imposition of long terms of parole does not amount to cruel
and unusual punishment. See State v. Graham, 897 N.W.2d 476, 487–88 (Iowa
Outcome: In light of our supreme court’s controlling precedent on the issue, we
affirm the district court’s denial of Coleman’s PCR application. See State v.
Beck, 854 N.W.2d 56, 64 (Iowa Ct. App. 2014) (“We are not at liberty to overrule controlling supreme court precedent.”).