People v. Parks
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2022 | State Juristiction

People v. Parks

Keywords Miller v. Alabama; Montgomery v. Louisiana ; juvenile offender; juvenile life without parole; mitigating factors of youth; adolescent brain development; cruel and unusual punishment; proportionality

Abstract

In this case, the Michigan Supreme Court ruled that mandatory life-without-parole sentences for 18-year-olds violate the Michigan Constitution's ban on "cruel or unusual" punishment. The court found that these sentences lack proportionality because they do not take into account the mitigating characteristics of youth, specifically late-adolescent brain development.   The court's decision was based on the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana, which held that mandatory life-without-parole sentences for juveniles are unconstitutional. However, the Michigan Supreme Court went further and applied these principles to defendants who were 18 at the time of their crimes.

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Abstract

In this case, the Michigan Supreme Court ruled that mandatory life-without-parole sentences for 18-year-olds violate the Michigan Constitution's ban on "cruel or unusual" punishment. The court found that these sentences lack proportionality because they do not take into account the mitigating characteristics of youth, specifically late-adolescent brain development.   The court's decision was based on the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana, which held that mandatory life-without-parole sentences for juveniles are unconstitutional. However, the Michigan Supreme Court went further and applied these principles to defendants who were 18 at the time of their crimes.

Summary

The Michigan Supreme Court determined that mandatory life-without-parole sentences for individuals aged 18 are unconstitutional under the Michigan Constitution's prohibition of "cruel or unusual" punishment. The court's rationale centered on the concept of proportionality, arguing that such sentences fail to adequately consider the mitigating factors associated with youth, particularly the ongoing development of the adolescent brain.

This decision was informed by the U.S. Supreme Court's precedents in Miller v. Alabama and Montgomery v. Louisiana, which declared mandatory life-without-parole sentences for juveniles unconstitutional. Notably, the Michigan Supreme Court extended these principles to individuals who were 18 years old at the time of their offenses, expanding the scope of constitutional protection.

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Abstract

In this case, the Michigan Supreme Court ruled that mandatory life-without-parole sentences for 18-year-olds violate the Michigan Constitution's ban on "cruel or unusual" punishment. The court found that these sentences lack proportionality because they do not take into account the mitigating characteristics of youth, specifically late-adolescent brain development.   The court's decision was based on the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana, which held that mandatory life-without-parole sentences for juveniles are unconstitutional. However, the Michigan Supreme Court went further and applied these principles to defendants who were 18 at the time of their crimes.

Summary

The Michigan Supreme Court has ruled that mandatory life-without-parole sentences for individuals aged 18 violate the Michigan Constitution's prohibition against "cruel or unusual" punishment. This ruling, aligning with U.S. Supreme Court decisions in Miller v. Alabama and Montgomery v. Louisiana, emphasizes the lack of proportionality in such sentences due to the ongoing developmental stage of the brain during late adolescence. This reasoning extends the protections previously granted to juveniles to individuals who were 18 years old at the time of their offense.

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Abstract

In this case, the Michigan Supreme Court ruled that mandatory life-without-parole sentences for 18-year-olds violate the Michigan Constitution's ban on "cruel or unusual" punishment. The court found that these sentences lack proportionality because they do not take into account the mitigating characteristics of youth, specifically late-adolescent brain development.   The court's decision was based on the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana, which held that mandatory life-without-parole sentences for juveniles are unconstitutional. However, the Michigan Supreme Court went further and applied these principles to defendants who were 18 at the time of their crimes.

Summary

The Michigan Supreme Court decided that mandatory life sentences without the possibility of parole for 18-year-olds are unconstitutional. The court ruled that these sentences are too harsh because they don't consider the fact that young adults' brains are still developing.

The court based its decision on rulings from the U.S. Supreme Court that found mandatory life-without-parole sentences for teenagers are unconstitutional. The Michigan Supreme Court extended these rulings to include individuals who were 18 years old when they committed their crimes.

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Abstract

In this case, the Michigan Supreme Court ruled that mandatory life-without-parole sentences for 18-year-olds violate the Michigan Constitution's ban on "cruel or unusual" punishment. The court found that these sentences lack proportionality because they do not take into account the mitigating characteristics of youth, specifically late-adolescent brain development.   The court's decision was based on the U.S. Supreme Court's rulings in Miller v. Alabama and Montgomery v. Louisiana, which held that mandatory life-without-parole sentences for juveniles are unconstitutional. However, the Michigan Supreme Court went further and applied these principles to defendants who were 18 at the time of their crimes.

Summary

The Michigan Supreme Court said that it's not fair to give someone who was 18 years old a life sentence without the chance to ever get out of prison. The court said this kind of punishment is too harsh because it doesn't consider that young adults are still developing their brains.

The Michigan court based its decision on what the U.S. Supreme Court said in some other cases. The U.S. Supreme Court already said that it's wrong to give kids a life sentence without the possibility of getting out of prison. The Michigan court took this idea one step further and said it also applies to people who were 18 years old when they did something wrong.

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Footnotes and Citation

Cite

987 N.W.2d 161 (Mich. 2022)

Highlights