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Case No. 19-1344

Michael Eugene Horlas
State of Iowa


Michael Eugene Horlas


State of Iowa

Attorney for the Appellant

Lauren M. Phelps

Attorney for the Appellee

Darrel Mullins, Assistant Attorney General

Court of Appeals

Court of Appeals Opinion

Opinion Number:
Date Published:
Oct 07, 2020

            Appeal from the Iowa District Court for Scott County, John Telleen, Judge.  AFFIRMED.  Considered by Bower, C.J., and May and Ahlers, JJ.  Opinion by Bower, C.J.  (5 pages)

            Michael Eugene Horlas appeals the denial of his application for postconviction relief, contending his sentence of life imprisonment amounts to cruel and unusual punishment in violation of the Eight Amendment to the United States Constitution and Article I, section 17 of the Iowa Constitution.  OPINION HOLDS: We find no Iowa case law that supports Horlas’s argument to extend the holding of Atkins v. Virginia, 536 U.S. 304, 321 (2002)—finding it unconstitutional to impose the death penalty on intellectually disabled defendants—to mentally-ill persons serving a life sentence.

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