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Fairfield, Iowa, teacher murder conviction upheld by Iowa Supreme Court

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A then-16-year-old student who plotted to kill his Spanish teacher must serve at least 35 years in prison before being eligible for parole, the Iowa Supreme Court confirmed Friday.

Willard Chaiden Miller and his friend Jeremy Goodale have been charged with the 2021 murder of teacher Nohema Graber, who was found bludgeoned to death and hiding under a railroad tie and other debris in a Fairfield park.

Goodale later told investigators that Miller was upset about his grade in Graber's class and that Goodale had agreed to help Miller ambush her with a baseball bat as she walked through the park.

Both teenagers pleaded guilty and were sentenced to life in prison. However, since they were minors, they may not be required to serve the full sentence. Instead, Miller was sentenced to a minimum sentence of 35 years before being eligible for parole, while Goodale received a minimum sentence of 25 years.

Under state law, there is a “presumption” against mandatory minimum sentences for juveniles and these can only be imposed on an individual basis, taking into account the defendant’s background and his or her rehabilitation options. The Supreme Court has stated that “the default rule…is that (juveniles) are not subject to a minimum period of detention.”

However, in Miller's case, the judge made it clear that he believed a long minimum sentence was appropriate. Judge Shawn Showers even told Miller that he would have “seriously considered” a life sentence without parole if the law had allowed it.

At his trial, Miller argued that he should be granted immediate probation. On appeal, his lawyers said Showers erred by ignoring the presumption against minimum sentences for juveniles.

Even if Showers had followed the law, Miller said applying a mandatory minimum sentence to juveniles should be unconstitutional in all circumstances, even if individual hearings are beneficial.

Court: Compulsory sentences are still constitutional

Chief Justice Susan Christensen, writing for the unanimous court, noted in her opinion that the court previously heard similar constitutional challenges to juvenile sentencing in 2018. In any case, the court agreed that in some cases it is appropriate to sentence young offenders to mandatory minimum sentences.

“Frankly, little has changed in the six years since (2018),” Christensen wrote, explaining that precedent alone was enough to thwart Miller’s constitutional claim.

The court also rejected Miller's argument that prosecutors are required to provide expert testimony on a particular defendant's “youthful characteristics” when seeking a minimum sentence. Christensen wrote that the few states that have considered similar arguments have determined that expert testimony is not required, and that neither state law nor the Iowa Constitution provides for such a requirement.

And after upholding the constitutionality of Iowa's juvenile sentencing system, the Supreme Court concluded that Showers had properly considered the proper factors before imposing Miller's minimum sentence.

“The harm to Graber and her family is no less because Miller committed the crime as a juvenile,” Christensen wrote. “Youth is a mitigating factor, not an excuse.”

An appeals attorney representing Miller did not immediately return a message seeking comment on the ruling.

According to the court, Miller wrote a threatening message while in custody

The statement discusses in detail evidence from Miller's case and sentencing process, including previously sealed details about Miller's time in a juvenile detention center while awaiting trial.

During his 18 months in custody, Miller was repeatedly punished for infractions ranging from horseplay to arguments with staff and “verbal attacks.” But most “disturbing,” as Christensen put it, was a “seemingly threatening message” from Miller that was intercepted by an employee. The note described the name and appearance of another student, giving police important information about him. It also detailed where the student typically parks, what car the student drove, and other details about the student's schedule.

The decision does not specify who the note was intended for.

William Morris covers the Des Moines Register courts. He can be contacted at [email protected] or 715-573-8166.

By Vanessa

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