Nathan Dominic Curtis, Applicant-Appellant v. State of Iowa, 16-0562

In May 2004, then-18-year-old Nathan Curtis robbed a woman at knifepoint, taking her gym bag. He was convicted of first-degree robbery (class B felony).
The district court sentenced Curtis to up to 25 years’ incarceration with a mandatory minimum of 70% under Iowa law.
In December 2014 Curtis filed a postconviction relief (PCR) application alleging ineffective assistance of counsel and later amended to challenge the mandatory minimum as cruel and unusual punishment and to seek an individualized sentencing hearing because he was 18 at the time of the offense.
The district court dismissed Curtis’s claims; Curtis appealed. The court treated the appeal as a petition for writ of certiorari to review claims that his sentence was illegal and unconstitutional.
Curtis urged the court to extend State v. Lyle to bar mandatory minimums for offenders age 25 or younger (or alternatively for all defendants) and to require individualized sentencing hearings for those subject to mandatory minimums.
The Court of Appeals declined to extend Lyle beyond defendants under 18 and affirmed the dismissal, annulling the writ.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Curtis’s mandatory minimum sentence constitutes cruel and unusual punishment under the Eighth Amendment and Iowa Constitution	Curtis argued the mandatory 70% minimum is unconstitutional for him as a youthful offender (he was 18) and urged a categorical extension of Lyle to offenders 25 or younger or to all defendants; he sought individualized sentencing consideration	State argued Lyle applies only to offenders under 18 and should not be extended; mandatory minimum was lawful as applied to an adult offender	Court held Lyle is limited to those under 18; declined to extend it to age 25 or to all defendants and affirmed dismissal

Bonilla v. State, 791 N.W.2d 697 (Iowa 2010) (standard: constitutional claims reviewed de novo; illegal sentence may be corrected at any time)
State v. Lyle, 854 N.W.2d 378 (Iowa 2014) (held mandatory minimums unconstitutional for youthful offenders under 18 under Iowa Constitution)
State v. Eichler, 83 N.W.2d 576 (Iowa 1957) (appellate court should not overrule Supreme Court precedent)
State v. Hastings, 466 N.W.2d 697 (Iowa Ct. App. 1990) (appellate court may not overturn Iowa Supreme Court precedent)