Balah Hasson Rushing, Applicant-Appellant v. State of Iowa, 15-1388

In 2014 Balah Rushing pled guilty to second-degree robbery and received a 10-year sentence with a 7-year mandatory minimum.
Rushing was 18 years, 7 months old at the time of the offense. He did not appeal his conviction.
In 2015 he applied for postconviction relief, arguing mandatory minimums were unconstitutional as applied to him because of his youth, relying on State v. Null and related juvenile-sentencing cases.
The district court denied relief, concluding Null and its progeny apply only to juvenile offenders.
On appeal Rushing asked the court to extend State v. Lyle’s reasoning to offenders under age 21.
The appellate court affirmed, noting it was bound by Iowa Supreme Court precedent that limits Lyle’s holding to juvenile offenders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandatory minimum sentence is unconstitutional for an 18‑year‑old	Rushing: Youthful age (under 21) and brain-development science make mandatory minimums cruel and unusual	State: Controlling precedent confines the juvenile-sentencing rule to juveniles; adult sentencing laws unchanged	Denied — court bound by precedent; Lyle and related cases do not apply to adult offenders

State v. Null, 836 N.W.2d 41 (Iowa 2013) (recognized need for individualized sentencing for juveniles based on brain development and diminished culpability)
State v. Pearson, 836 N.W.2d 88 (Iowa 2013) (joined Null in establishing juvenile sentencing protections)
State v. Ragland, 836 N.W.2d 107 (Iowa 2013) (juvenile sentencing considerations and individualized hearings)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (held mandatory minimums unconstitutional for juvenile offenders; expressly limited holding to juveniles)
State v. Sweet, 879 N.W.2d 811 (Iowa 2016) (declined to depart from Lyle’s reasoning)
State v. Beck, 854 N.W.2d 56 (Iowa Ct. App. 2014) (appellate court note on adherence to supreme court precedent)