## Facts

- Sixteen-year-old Keyon Harrison and Keith Collins planned to rob marijuana dealer Aaron McHenry.
- Harrison acted as a decoy to place McHenry in a vulnerable position; Collins brought a gun.
- During the robbery, McHenry and Collins struggled over the firearm; the gun discharged, killing McHenry.
- Harrison was unarmed.
- The State charged Harrison as an adult with first-degree murder under Iowa’s felony-murder rule, alleging he aided and abetted the robbery that resulted in death.
- A jury convicted Harrison of first-degree felony murder.
- The court imposed life imprisonment with immediate eligibility for parole.

## Issues

1. Whether Iowa’s felony-murder statute violates due process by creating a conclusive presumption of malice (or its equivalent) from participation in the predicate felony, including as applied to a juvenile.
2. Whether sentencing a juvenile felony-murder accomplice to life imprisonment with immediate parole eligibility is cruel and unusual punishment, either categorically for juveniles convicted of felony murder or as applied to Harrison.

## Decision

- The Iowa Supreme Court affirmed Harrison’s conviction.
- The court held Iowa’s felony-murder statute is a substantive definition of first-degree murder and does not create an unconstitutional presumption of malice.
- The court rejected inserting a foreseeability-of-death element into felony murder and held foreseeability is irrelevant under Iowa law.
- The court affirmed the sentence, holding life with immediate parole eligibility for a juvenile is not cruel and unusual punishment.
- The court held the sentence was not grossly disproportionate as applied to Harrison given his participation in a planned armed robbery that resulted in death.

## Legal Principles

- A felony-murder statute may constitutionally define murder by requiring intent to commit an enumerated predicate felony plus a death occurring during participation in that felony, without requiring proof of intent to kill.
- Treating felony murder as a substantive offense definition is distinct from creating an evidentiary presumption; due process is not violated when the State must prove the statute’s defined elements beyond a reasonable doubt.
- Under Iowa felony murder, foreseeability of death is not an element, and courts need not add a foreseeability requirement for juvenile defendants.
- The Eighth Amendment permits a juvenile life sentence if the defendant has a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation; immediate parole eligibility satisfies that requirement.
- For proportionality review under Iowa law, a life sentence with immediate parole eligibility for a juvenile felony-murder participant is not grossly disproportionate when the underlying forcible felony is serious and results in death.

## Conclusion

Iowa upheld felony-murder liability for a juvenile unarmed accomplice based on intent to commit the underlying robbery and a resulting death, and it held that life imprisonment with immediate parole eligibility provides a constitutionally adequate opportunity for release and is not cruel and unusual punishment.


State v. Harrison, 914 N.W.2d 178 (Iowa 2018)