People v. Carp
SummaryOriginal

Summary

Michigan Supreme Court refused to retroactively apply Miller v. Alabama, upholding juvenile life without parole sentences. The court also found no Eighth Amendment or state constitutional bar to such sentences.

2014 | State Juristiction

People v. Carp

Keywords child convicted of murder; individualised sentence; LWOP; retroactive application of Miller; Miller v. Alabama; Eighth Amendment (U.S.); juvenile offenders; cruel and unusual punishment; Michigan Constitution; sentencing guidelines

Abstract

People v. Carp (2014) involved three consolidated cases before the Michigan Supreme Court concerning juvenile life without parole sentences. Following the U.S. Supreme Court's decision in Miller v. Alabama (2012), which prohibited mandatory life without parole sentences for juveniles, the Michigan court considered whether Miller applied retroactively to these cases. The court determined Miller did not satisfy the retroactivity tests under either federal precedent or the independent Michigan standard. Additionally, the court rejected the argument that the Eighth Amendment or the Michigan Constitution categorically barred life without parole sentences for juvenile offenders.

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Abstract

People v. Carp (2014) involved three consolidated cases before the Michigan Supreme Court concerning juvenile life without parole sentences. Following the U.S. Supreme Court's decision in Miller v. Alabama (2012), which prohibited mandatory life without parole sentences for juveniles, the Michigan court considered whether Miller applied retroactively to these cases. The court determined Miller did not satisfy the retroactivity tests under either federal precedent or the independent Michigan standard. Additionally, the court rejected the argument that the Eighth Amendment or the Michigan Constitution categorically barred life without parole sentences for juvenile offenders.

In People v. Carp (2014), the Michigan Supreme Court addressed the implications of Miller v. Alabama (2012) on three consolidated cases concerning juvenile life without parole (JLWOP) sentences. The Miller precedent, established by the U.S. Supreme Court, prohibited mandatory JLWOP sentences. The Michigan court, however, determined that the Miller ruling did not possess retroactive application under established federal precedent or the distinct legal framework of Michigan. Furthermore, the court refuted the assertion that the Eighth Amendment to the U.S. Constitution or the analogous provision within the Michigan Constitution categorically proscribed JLWOP sentences.

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Abstract

People v. Carp (2014) involved three consolidated cases before the Michigan Supreme Court concerning juvenile life without parole sentences. Following the U.S. Supreme Court's decision in Miller v. Alabama (2012), which prohibited mandatory life without parole sentences for juveniles, the Michigan court considered whether Miller applied retroactively to these cases. The court determined Miller did not satisfy the retroactivity tests under either federal precedent or the independent Michigan standard. Additionally, the court rejected the argument that the Eighth Amendment or the Michigan Constitution categorically barred life without parole sentences for juvenile offenders.

The Michigan Supreme Court heard three combined cases in People v. Carp (2014) regarding juvenile life sentences without the possibility of parole. This followed the U.S. Supreme Court's ruling in Miller v. Alabama (2012), which determined that mandatory life sentences without parole for minors were unconstitutional. The Michigan court had to determine if the Miller decision applied retroactively to these specific cases. Ultimately, the court concluded that Miller did not meet the necessary criteria for retroactivity under established federal precedent or Michigan's own standards. Furthermore, the court dismissed the argument that life sentences without parole for juvenile offenders were fundamentally prohibited by the Eighth Amendment or the Michigan Constitution.

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Abstract

People v. Carp (2014) involved three consolidated cases before the Michigan Supreme Court concerning juvenile life without parole sentences. Following the U.S. Supreme Court's decision in Miller v. Alabama (2012), which prohibited mandatory life without parole sentences for juveniles, the Michigan court considered whether Miller applied retroactively to these cases. The court determined Miller did not satisfy the retroactivity tests under either federal precedent or the independent Michigan standard. Additionally, the court rejected the argument that the Eighth Amendment or the Michigan Constitution categorically barred life without parole sentences for juvenile offenders.

People v. Carp (2014) was a really important case in Michigan that dealt with whether kids could be sentenced to life in prison without the possibility of parole (LWOP). Basically, the case combined three separate cases where teenagers were given LWOP sentences.

Here's the problem: a few years before, the U.S. Supreme Court ruled in Miller v. Alabama (2012) that automatically giving kids LWOP was unconstitutional. This meant judges had to consider other options and couldn't just give that sentence out automatically.

So, in People v. Carp, the Michigan Supreme Court had to figure out if this new rule from Miller v. Alabama applied to the cases of these three individuals who were sentenced before the ruling. The court ultimately decided that the Miller rule didn't apply to these cases because of how the law looks at whether new rules apply to old cases.

Furthermore, the court decided against the argument that giving kids LWOP was always unconstitutional, whether under the U.S. Constitution or the Michigan Constitution.

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Abstract

People v. Carp (2014) involved three consolidated cases before the Michigan Supreme Court concerning juvenile life without parole sentences. Following the U.S. Supreme Court's decision in Miller v. Alabama (2012), which prohibited mandatory life without parole sentences for juveniles, the Michigan court considered whether Miller applied retroactively to these cases. The court determined Miller did not satisfy the retroactivity tests under either federal precedent or the independent Michigan standard. Additionally, the court rejected the argument that the Eighth Amendment or the Michigan Constitution categorically barred life without parole sentences for juvenile offenders.

In 2014, the Michigan Supreme Court heard three cases together about kids getting life in prison without parole. These cases were called People v. Carp. A little while before, the U.S. Supreme Court had decided in Miller v. Alabama that it was wrong to automatically give kids life without parole. The Michigan court had to figure out if the Miller rule applied to these older cases.

The court decided the Miller rule didn't change things for these older cases. They said the way the law works for going back and changing old cases didn't fit with the Miller situation. Also, the court said that giving kids life without parole wasn't always wrong according to the Constitution.

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Footnotes and Citation

Cite

People v. Carp, 852 N.W.2d 801 (Mich. 2014)

Highlights