State of Iowa v. Damion John Seats

This is a difficult case presenting two important issues: First, are life-without-parole sentences for juvenile murderers categorically unconstitutional? Second, even if such sentences are not categorically *564unconstitutional, do the facts of this case permit such a sentence?

Unfortunately, the court decides neither issue. Instead, it remands the case for an unneeded procedural do-over in which the district court is directed to reapply caselaw it has already applied. This remand not only leaves the present case unresolved, but also provides no helpful guidance to our district courts in other…