Extension of Parks: Individualized Sentencing Required Before LWOP for 19- and 20-Year-Old First-Degree Murderers

Introduction

This commentary examines the Michigan Supreme Court’s April 10, 2025 decision in People of Michigan v. Andrew Michael Czarnecki and People of Michigan v. Montario Marquise Taylor. It addresses the Court’s extension of the rule from People v. Parks—which abolished mandatory life without parole (LWOP) for first-degree murderers who were 18 at the time of the crime—to defendants who were 19 or 20 years old when they committed their offenses. The decision holds that mandatorily sentencing late adolescents to LWOP violates the proportionality requirement of Michigan’s Constitution (Art. 1, § 16) and requires individualized sentencing procedures under MCL 769.25 (and 769.25a) before imposing LWOP on this class of offenders.

Case Background and Key Issues

Defendant Czarnecki (Docket No. 166654) was convicted of first-degree premeditated murder for a killing committed when he was 19. Under MCL 750.316(1)(a), he received mandatory LWOP. On appeal, the Michigan Court of Appeals affirmed, holding that Parks applied only to 18-year-olds and did not overrule People v. Hall (1978), which upheld mandatory LWOP for felony murder.
Defendant Taylor (Docket No. 166428) was convicted of first-degree premeditated murder and felony-firearm for a killing committed when he was 20. He also received mandatory LWOP. On remand after Parks, the Court of Appeals again held Hall binding and declined to extend Parks.
The Supreme Court consolidated both applications and directed briefing and argument on whether the Parks rule should extend to 19- and 20-year-olds and whether overruling Hall was required.
The primary constitutional question: Does mandatory LWOP for first-degree murder committed at ages 19 or 20 violate Michigan’s prohibition on “cruel or unusual punishment” (Art. 1, § 16)?

Summary of the Judgment

In an opinion by Justice Welch (joined by Justices Bernstein, Cavanagh, Bolden, and Thomas), the Court:

Extended Parks to include offenders who were 19 or 20 at the time of their first-degree murder convictions.
Held that mandatory LWOP for these late-adolescent defendants violates the principle of proportionality under Const. 1963, Art. 1, § 16.
Confirmed that 19- and 20-year-old offenders remain eligible for LWOP but only after an individualized sentencing hearing under the procedures of MCL 769.25 (and 769.25a), with a rebuttable presumption against LWOP that the prosecutor must overcome by clear and convincing evidence.
Applied the decision retroactively to cases on collateral review.
Declined to overrule Hall, finding Hall still viable for offenders aged 21 and older at the time of their offense.
Remanded both cases for resentencing in accordance with MCL 769.25 and the Court’s precedents.

Analysis

Precedents Cited

Parks (510 Mich 225, 2022): Held that mandatory LWOP for 18-year-olds violates Art. 1, § 16 and entitles them to individualized sentencing under MCL 769.25.
Lorentzen (387 Mich 167, 1972) & Bullock (440 Mich 15, 1992): Established the four-factor proportionality test for “cruel or unusual punishment.”
Miller v. Alabama (567 US 460, 2012) & Montgomery v. Louisiana (577 US 190, 2016): Federal decisions recognizing the relevance of youth to Eighth Amendment proportionality analysis.
Hall (396 Mich 650, 1978): Upheld mandatory LWOP for felony murder of a 17-year-old under Art. 1, § 16; reaffirmed as binding for offenders 21 and older in the current decision.

Legal Reasoning

The Court applied the four-factor proportionality analysis under Art. 1, § 16:

Gravity of Offense vs. Severity of Punishment: First-degree premeditated murder is among the gravest crimes and LWOP is the harshest penalty. However, the Court found that mandatorily condemning 19- and 20-year-olds—whose brain development remains more like juveniles than adults—without individualized consideration is grossly disproportionate.
Michigan’s Other Sentences: LWOP is reserved for a narrow set of offenses. The Legislature’s preference for rehabilitation means that permanently foreclosing release for late adolescents—who have high prospects for reform—undermines proportionality.
Other Jurisdictions: Michigan is one of a minority of jurisdictions mandating automatic LWOP for first-degree murder. Federal law and a majority of states impose discretionary or term-of-years sentences, and some foreign systems prohibit LWOP for late adolescents entirely. These “evolving standards of decency” trend against mandatory LWOP for the late-adolescent class.
Rehabilitation: Michigan’s constitutional history and long practice emphasize rehabilitation. LWOP denies the opportunity for growth and release, conflicting with the state’s penological goals for a class of offenders with greater potential for change.

Balancing these factors, the Court concluded that mandatory LWOP for offenders who were 19 or 20 at the time of their crime violates Article 1, § 16’s prohibition on cruel or unusual punishment.

Impact on Future Cases and Michigan Law

Broader Class Protected: The decision extends individualized sentencing protections—initially recognized for 18-year-olds—to all first-degree murderers who were under 21 at the time of their offense.
MCL 769.25 Hearings: Prosecutors must move for LWOP under MCL 769.25 or 769.25a, triggering a rebuttable presumption against LWOP, with the court required to weigh youth-related mitigating factors.
Retroactivity: Applies retroactively, enabling collateral review for affected inmates sentenced under mandatory LWOP statutes.
Legislative Consideration: By drawing the line at age 21, the Court invites the Legislature to evaluate whether further adjustment is warranted—either by extending protection to older cohorts or refining sentencing procedures.

Complex Concepts Simplified

“Cruel or Unusual Punishment” (Art. 1, § 16): Michigan’s Constitution forbids punishments that are excessively harsh compared to the crime and offender—a broader standard than the federal “cruel and unusual” clause.
Proportionality Test: Courts balance four factors: (1) crime vs. punishment severity, (2) similar penalties in Michigan, (3) how other jurisdictions punish the same crime, and (4) the goal of rehabilitation.
MCL 769.25 & 769.25a (“Miller Hearings”): Statutes requiring special sentencing procedures when LWOP is sought for youthful offenders. They set a rebuttable presumption against LWOP and mandate consideration of youth-related factors.
“Evolving Standards of Decency”: A legal principle that societal views of acceptable punishment change over time; courts may look at other states and countries to gauge those trends.

Conclusion

The Michigan Supreme Court’s extension of its Parks decision to include those who were 19 or 20 at the time of a first-degree murder conviction marks a significant development in the state’s Eighth Amendment jurisprudence. By holding that mandatory LWOP for late adolescents is unconstitutionally disproportionate under Article 1, § 16, the Court has expanded individualized sentencing protections and reaffirmed Michigan’s commitment to proportionality and rehabilitation. This ruling will shape resentencing hearings, affect collateral-review petitions, and prompt legislative review of Michigan’s sentencing statutes to ensure that they align with constitutional requirements and contemporary standards of decency.