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Michael Eugene Horlas
v.
State of Iowa
Appellant
Michael Eugene Horlas
Appellee
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:
Summary
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.
