Fairfield teen who killed Spanish teacher denied appeal, sentencing upheld

DES MOINES — The Iowa Supreme Court Friday upheld the 35-year mandatory minimum sentence of up to a life term for Willard Chaiden Miller, who at 16, murdered his high school Spanish teacher in 2021, ruling the trial judge didn’t abuse his discretion and followed all the required factors of law.

Chief Justice Susan Christensen, writing for the majority, said 8th Judicial District Judge Shawn Showers gave a “thorough explanation” for his sentencing decision, considering every the 22 factors, regarding characteristics of youth, which are required when sentencing a juvenile. The court’s sentencing decision didn’t violate the Iowa Constitution, which Miller asserted in his appeal.

Miller, along with Jeremy Goodale, also convicted of first-degree murder, killed Nohema Graber, 66, with a baseball bat on Nov. 2, 2021 in a park near Fairfield High School. Goodale also was sentenced up to life but he must serve a mandatory minimum of 25 years before being eligible for parole.

In previous rulings regarding juvenile sentencings for first-degree murder, the court has found the Iowa Constitution doesn’t “categorically prohibit” sentencing juveniles to a minimum term before being eligible for parole, Christensen said in the ruling. She listed examples of “multiple” rulings the court has made involving juvenile offenders which included a mandatory minimum of a life sentence.

Miller also argued the prosecution had to present expert testimony in favor of the mandatory minimum, which it didn’t, but the Iowa Legislature hasn’t established it as a requirement, just as there is no “national consensus,” on that issue, the ruling states.

“Though ‘juveniles may be more prone to reform and rehabilitation because of their age and the attendant characteristics of youth, they must also understand the severity of their actions,’” Christensen, quoting another case law ruling, said. “The harm to Graber and her family is no less because Miller committed the crime as a juvenile. Youth is a mitigating factor, not an excuse.”

The juvenile sentencing factors a trial court judge must consider are “tools for weighing juvenile culpability,” so the court can make a “punishment that serves the best interests of the child and society.” Requiring an expert in every juvenile sentencing doesn’t serve that goal. The goal is already accomplished when a trial judge considers the required juvenile sentencing factors.

Miller’s appeal also asserted the district court made an “improper assessment” in concluding Miller downplayed his role in the crime and failed to show remorse. However, the district court found Miller’s acceptance of responsibility “to be a mitigating factor” because he spared Graber’s family, witnesses and the Fairfield community from going through a trial where details of this ‘brutal act’ would be repeated more than once. The justices found no improper assessments were made by the trial judge, according to the ruling.

The ruling states, when the presentencing probation officer asked Miller how he felt “emotionally” on a daily basis, Miller said “‘confident and collected.’” The ruling pointed out that Miller, during his sentencing allocution, spent a significant time talking about himself and his desire to reenter society.

Miller said “I’m planning on getting back out there as soon as I can to make up for the lost time,” and he hoped Goodale also “gets out as soon as possible.” He also said he didn’t want to be “institutionalized” and be in prison “so long that I forget about what matters, where I come from, and what I need to do. I look forward to getting through this,” he said.

The ruling also pointed out that Miller, in his guilty plea, consistently maintained that Goodale was the only one to strike Graber with the bat while he acted as lookout “despite evidence to the contrary.” Miller told the presentencing author “At first, I felt I couldn’t be guilty because I did not actually hit Mrs. Graber. I only touched Mrs. Graber one time with my foot while moving her. In looking back, I see I made the plan, and I brought the bat.”

At sentencing, Miller said he “‘accepted responsibility for his carelessness, for his ignorance,’” the ruling states.

Showers, during sentencing, pointed out Miller waited until “’today to show some sort of remorse for the act that you and Mr. Goodale committed,’” according to the ruling. “’I find that you downplayed your role in this homicide based on your admissions and minutes of testimony and the evidence presented in this sentencing hearing. It’s an aggravating factor.’”

Showers, also noted Miller told a classmate that “you caught a body with a baseball bat.”

“While the defendant is remorseful for his current situation, there has been little remorse shown by Mr. Miller for Nohema Graber, her family,” Showers said during sentencing.

The record supports the observations of the trial court, the ruling states. Miller’s life sentence with the possibility of parole after serving 35 years was affirmed by the court.

Both teens are serving their sentences at the Iowa State Penitentiary in Fort Madison.

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