State v. Harrison

Keyon Harrison was 16-years-old and unarmed when an older acquaintance used him as a decoy in the robbery of a local drug dealer. During the robbery, the victim fought with Harrison’s armed co-defendant over his gun, and the gun went off killing the victim. Harrison was convicted of felony murder and sentenced to life with the possibility of parole in the adult justice system.

Juvenile Law Center, along with Center on Wrongful Convictions of Youth and Center for Law, Brain and Behavior filed an amicus brief in the Iowa Supreme Court on behalf of Mr. Harrison. We argued that the rationale underlying the felony murder doctrine contravenes Supreme Court Jurisprudence as applied to juveniles who are categorically less culpable than adults and lack the foreseeability necessary to be held liable under the felony murder doctrine.

The Iowa Supreme Court upheld Mr. Harrison’s sentence, holding that the felony-murder rule does not “violate[ ] the Due Process Clauses of the Iowa or United States Constitutions and that “foreseeability is irrelevant to the felony-murder rule and Harrison’s alleged inability to foresee the consequences of his decision to participate in a robbery is likewise irrelevant to his conviction.” The court further held that sentencing a juvenile to “life imprisonment with immediate parole eligibility does not constitute cruel and unusual punishment, either categorically or as applied to Harrison.”