State v. Seats
| Decision Date | 26 June 2015 |
| Docket Number | No. 13–1960.,13–1960. |
| Citation | 865 N.W.2d 545 |
| Parties | STATE of Iowa, Appellee, v. Damion John SEATS, Appellant. |
| Court | Iowa Supreme Court |
F. David Eastman of Eastman Law Office, Clear Lake, for appellant.
Thomas J. Miller, Attorney General, and Alexandra Link, Assistant Attorney General, for appellee.
Alan Ostergren, Muscatine, for amicus curiae, Iowa County Attorneys Association.
A juvenile offender convicted of first-degree murder appeals his resentencing to life in prison without the possibility of parole. In this appeal, we determine the factors a court must use when it sentences a juvenile offender for first-degree murder. Because the district court did not have the benefit of this decision when it sentenced the juvenile, we vacate the sentence and remand for resentencing. We do not reach the issue as to whether a sentence of life in prison without parole categorically violates the Iowa Constitution's prohibition against cruel and unusual punishment, because we are remanding the case for resentencing.
On August 23, 2008, Damion Seats, who was seventeen years old at the time, went to a party at a friend's house in Mason City. While at the party, Seats's friend, Andre Wells revealed he had a handgun in his pocket. In the early morning hours of August 24, Seats and Wells convinced another friend, Jamie McFarland, to give them and two acquaintances a ride from the party to Reuben Ramirez's house.
Earlier that month, Seats initiated a fight with Ramirez at Ramirez's house. During the fight, Seats hit Ramirez on the head with a brick. On the evening of the party, Seats was concerned that Ramirez would report the brick incident to the police. Before leaving for Ramirez's house, Seats and Wells placed the loaded gun in the trunk of the car.
When the vehicle arrived at Ramirez's house, Seats instructed McFarland to park in the alley. Seats and Wells then tied t-shirts around their faces, retrieved the loaded handgun from the trunk, and entered the residence through a back door. When Seats and Wells entered the house Ramirez was not home, but Isidoro Cervantes Erreguin, who stayed with Ramirez at times, and Cervantes's brother were. Both were in the living room, asleep on different couches. Seats approached the living room couch where Cervantes was sleeping and shot him five times. Four of the bullets entered Cervantes's back and the fifth entered his chest. After Seats and Wells fled, paramedics arrived at Ramirez's house and attempted to perform CPR on Cervantes. The paramedics declared Cervantes dead at the scene.
Seats and Wells returned to McFarland's waiting car. After the group left Ramirez's house, Seats wrapped the handgun in a shirt and hid it under some bushes near his brother's apartment.
On the afternoon of August 24, Seats came to the police department and asked to speak with investigators. Seats met with the case agent assigned to lead the murder investigation, Division of Criminal Investigation Special Agent Chris Callaway. Seats had reportedly heard from his friends that the police mentioned his name as a possible suspect in Cervantes's murder. Seats stated he had come to the police station voluntarily in order to clear his name. Special Agent Callaway interviewed Seats for about two hours.
Seats recounted being at a friend's party on the night of the 23rd and said he stayed there until about 3:00 a.m. on the 24th. Seats acknowledged that after the party, he, Wells, and two acquaintances got a ride from McFarland. However, according to Seats, McFarland took the two acquaintances home, then dropped off Wells in a Walmart parking lot where Wells planned to meet up with another acquaintance. Seats told Special Agent Callaway that McFarland then drove him to another friend's house where he stayed the night. Seats stated he arrived at this friend's house around 4:00 a.m. on August 24 and slept there until about 11:00 a.m. He denied any involvement in the murder. The police permitted Seats to leave the station after the interview, but they continued to conduct surveillance on Seats.
While Special Agent Callaway was interviewing Seats, Wells came to the police department and turned over the gun Seats had hidden in the bushes. Based on Wells's version of events, the police arrested Seats that evening. The police brought Seats back to the station for another interview. This time Special Agent Callaway and Special Agent in Charge Jeff Jacobson were present and recorded the interview.
After Mirandizing Seats, the agents informed him they had recovered the gun and asked for his version of events. Seats initially continued to deny any involvement in the murder, but then told investigators he would tell them anything they wanted to know if he could speak to his girlfriend. The police allowed Seats to speak to both his girlfriend and his mother during the interview. When his mother asked him why he had shot Cervantes, he stated that he had intended to kill Ramirez to keep him from pressing charges. He went on to say, “I wasn't thinking of anybody this would've hurt if I got caught; I didn't think I was gonna get caught....” After the phone call to his mother, Seats drew a diagram of Ramirez's house and indicated where he entered the house, where the occupants were sleeping, and where he stood when he shot Cervantes. Seats also told investigators he felt remorse for shooting an innocent man.
AGENT: When did you realize it wasn't Reuben? A. Afterwards. Afterwards, like, I shot and I looked and, um, it ain't even him. And that's really what made me feel bad because that night, that dude wasn't even there. Like, he ain't even had nothing to do with that. So I killed an innocent person. That's what really ate me up, like, I killed somebody innocent who didn't have to die.
On September 9, the county attorney filed a trial information charging Seats, Wells, and McFarland jointly with first-degree murder and first-degree burglary. See Iowa Code §§ 707.1, .2 (2009); id. §§ 713.1, .3.
Notwithstanding his confession, Seats pled not guilty and went to trial separately from the other defendants. The jury found Seats guilty of both first-degree murder and first-degree burglary.
On October 26, 2009, as required by Iowa law, the court sentenced Seats to life without parole on the murder charge. See Iowa Code § 902.1 ( ). It also sentenced Seats concurrently to twenty-five years imprisonment on the burglary conviction. See id. § 902.9(2). The court of appeals affirmed his convictions.
On August 17, 2011, Seats filed a motion to correct an illegal sentence. At that time, Miller v. Alabama, 567 U.S. ––––, 132 S.Ct. 2455, 183 L.Ed.2d 407 (2012), was pending before the United States Supreme Court. The district court continued the hearing on Seats's motion until the Supreme Court rendered a decision. Shortly after Miller was decided, but before the trial court heard Seats's motion, Iowa's Governor commuted the sentences of all juveniles previously convicted of first-degree murder to a life sentence with the possibility of parole after sixty years. Seats requested and the district court granted a further postponement until we had decided a number of pending cases concerning this commutation and other aspects of juvenile sentencing.
On August 16, 2013, in State v. Ragland, we held the Governor's blanket commutation of the juveniles' life without parole sentences to life with eligibility for parole after sixty years did not affect the constitutional requirement that the district court proceed with an individualized hearing as required by Miller. See State v. Ragland, 836 N.W.2d 107, 121–22 (Iowa 2013). The district court scheduled an individualized resentencing hearing for Seats after the filing of the Ragland opinion.
In 2013, the court ordered a new presentence investigation report, which Barbara Brandt, a Mason City parole officer, prepared and filed. The report noted Seats had a difficult childhood, including a lack of adult supervision and exposure to gang violence at a very early age. It also indicated Seats had a history of homelessness and alcohol and drug abuse. The report indicated Seats had not graduated high school or completed his GED, but he had completed a literacy program while incarcerated. The report detailed Seats's juvenile criminal history. Seats told the parole officer that the majority of the people in his life had been negative influences, although some friends and associates in Mason City were positive influences. According to the report, Seats told the parole officer “[t]he difference between defendant and his co-defendants was that they had supportive family members and that wasn't the case for him.”
Additionally, the report noted the prison had disciplined Seats ten times, including for fighting, for possession of intoxicants, and twice for theft and unauthorized possession. Finally, the report indicated Seats held a job during his time in prison, but as of October 29, 2013, he was not employed due to his status. However, the report stated his case manager anticipated Seats would be eligible to work again in November 2013. The report did not make a sentencing recommendation because the court had previously sentenced Seats.
The court held a resentencing hearing on November 22. The court described the purpose of the proceeding as follows:
A series of U.S. Supreme Court cases and Iowa Supreme Court cases over the past several years have made clear that those two courts consider sentences of life without the opportunity for parole entered as to offenders who were juveniles at the time of the offense [to be] cruel and unusual punishment...
To continue reading
Request your trial
-
Planned Parenthood of the Heartland v. Reynolds ex rel. State
......Of course, "originalism is not the only available tool in constitutional interpretation." 915 N.W.2d 248 State v. Seats , 865 N.W.2d 545, 577 (Iowa 2015) (Mansfield, J., dissenting). But the majority wants it both ways. In the first part of its opinion, the majority quotes a number of broad, general pronouncements by the framers of our constitution at the 1857 convention. Yet the majority ignores that which is far ......
-
Davis v. State, S-16-0291
...... See, e.g., State v. Riley , 315 Conn. 637, 110 A.3d 1205, 1214 (2015) ; State v. Houston , 353 P.3d 55, 77, 83 (Utah 2015) ; State v. Seats , 865 N.W.2d 545, 555 (Iowa 2015) ; Hart , 404 S.W.3d at 241 ; Conley v. State , 972 N.E.2d 864, 871 (Ind. 2012) (requiring State to prove aggravating circumstances justifying life without the possibility of parole beyond a reasonable doubt). Further, we conclude, as did Pennsylvania and ......
-
Dorsey v. State
......Miller , Graham v. Florida , and Miller v. Alabama . See generally State v. Roby , 897 N.W.2d 127 (Iowa 2017) ; State v. Sweet , 879 N.W.2d 811 (Iowa 2016) ; State v. Louisell , 865 N.W.2d 590 (Iowa 2015) ; State v. Seats , 865 N.W.2d 545 (Iowa 2015) ; State v. Lyle , 854 N.W.2d 378 (Iowa 2014) ; State v. Ragland , 836 N.W.2d 107 (Iowa 2013) ; State v. Pearson , 836 N.W.2d 88 (Iowa 2013) ; State v. Null , 836 N.W.2d 41 (Iowa 2013). Dorsey relied specifically 975 N.W.2d 360 on State v. Lyle , in which ......
-
State v. Harrison, 16-1998
...that a sentencing court must consider "before sentencing a juvenile to life in prison without the possibility of parole." 865 N.W.2d 545, 555–57 (Iowa 2015). In applying these factors, we first established that "the presumption for any sentencing judge is that the judge should sentence juve......