U.S. Supreme Court rules no life sentences without parole for Michigan juveniles

The United States Supreme Court has ruled that juveniles convicted of first-degree murder cannot be subject to mandatory life sentences without parole. Because of their lesser culpability and greater capacity to change, they must be sentenced under a process that gives them an individualized opportunity to present mitigating circumstances to avert such a harsh sentence. In response, the Michigan legislature enacted legislation that purported to comply with the Court’s ruling, which included the possibility of being re-sentenced to prison for a term of years. However, the legislature provided that in calculating any such sentence, the youth offenders were not to receive any credit – known as good time or disciplinary credit – even though such credits were earned while the youth offenders served their illegally imposed sentences. In that respect, the legislative response ran afoul of our Constitution’s ban on ex post facto laws – the constitutional guarantee that laws may not retroactively criminalize conduct or enhance the punishment for criminal acts already perpetrated. For this reason, the Court must declare that provision of the statute unconstitutional and order that the youth offenders receive the credit that they have previously earned.
For the following reasons, the Court grants in part and denies in part Plaintiffs’ motion for partial summary judgment, declaratory judgment and permanent injunction; denies Defendants’ cross-motion for partial summary judgment; and grants Plaintiffs’ second renewed motion for class certification. The plaintiffs were individuals who were sentenced to mandatory life without parole for homicide crimes that they committed as juveniles. From the outset of the case over seven years ago, they have alleged that Michigan’s sentencing scheme violates their constitutional rights by depriving them of a meaningful opportunity for release – first challenging their mandatory sentences of life without parole, and now, in light of the Supreme Court’s decisions in Miller v. Alabama, 567 U.S. 460 (2012) and Montgomery v. Louisiana, 136 S. Ct. 718 (2016), they challenge Michigan’s statutes, policies, and procedures implemented in the post-Miller world. In Miller, the Supreme Court held that a mandatory sentence of life without parole for a juvenile offender convicted of homicide violated the Eighth Amendment’s prohibition on cruel and unusual punishment. In Montgomery, the Court held that Miller applied retroactively.
Michigan law had previously provided that youth offenders who were convicted of firstdegree murder were ineligible for parole. See Mich. Comp. Laws § 750.316 (life imprisonment without parole for first-degree murder); Mich. Comp. Laws § 791.234(6)(a) (ineligibility for parole for individuals convicted of first-degree murder under § 750.316). Following Miller, the Michigan legislature enacted new statutory provisions to ensure that juveniles convicted of first-degree murder would not be sentenced to mandatory life imprisonment without parole.2

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