Extension of Proportionality Protections: Individualized LWOP Sentencing for 19- and 20-Year-Old First-Degree Murder Offenders

Introduction

In People of Michigan v. Montario Marquise Taylor and People of Michigan v. Andrew Michael Czarnecki, the Michigan Supreme Court resolved whether its 2022 decision in People v. Parks—which held that mandatory life without parole (LWOP) for 18-year-old first-degree murderers violated the state Constitution’s prohibition on “cruel or unusual punishment”—should be extended to defendants who were 19 or 20 at the time of their crimes. Both defendants had received mandatory LWOP sentences under MCL 750.316 following jury convictions for first-degree premeditated murder, but neither underwent the individualized sentencing procedure now required for 18-year-olds under MCL 769.25. The Court’s unanimous majority, joined by five justices, extended Parks’ protections to late-adolescents aged 19 and 20. It held that Michigan’s Constitution (Const 1963, art 1, § 16) demands proportionality and evolving standards of decency in sentencing, and that mandatory LWOP for this age group is unconstitutionally disproportionate without individualized hearings. The rule applies retroactively on collateral review.

Summary of the Judgment

— The Court extended its 2022 holding in Parks from 18-year-olds to “late adolescents” aged 19 and 20 who are convicted of first-degree murder. Mandatory LWOP for these offenders violates the principle of proportionality and constitutes cruel punishment under Const 1963, art 1, § 16.

— Defendants Taylor (20 at the time of his offense) and Czarnecki (19 at the time) had each been sentenced to mandatory LWOP without individualized sentencing procedures. The Court vacated those LWOP sentences and remanded both cases for resentencing under MCL 769.25 or 769.25a, which require an individualized hearing addressing youth-related mitigating factors before LWOP can be imposed.

— The Court declined to overrule People v. Hall (1976), which had upheld mandatory LWOP for 17-year-olds, reasoning that Hall did not address the as-applied constitutional challenge and remains viable for offenders aged 21 or older at the time of the offense.

— The decision applies retroactively to cases on collateral review, following People v. Poole (2025).

Analysis

1. Precedents Cited

People v. Parks (2022): Held that mandatory LWOP for 18-year-olds violates Michigan’s “cruel or unusual punishment” clause and requires individualized sentencing under MCL 769.25.
People v. Lorentzen (1972) and People v. Bullock (1992): Established Michigan’s four-factor proportionality test under Const 1963, art 1, § 16:

Severity of the punishment vs. gravity of the offense
Penalty compared with other offenses in Michigan
Michigan’s penalty compared with other jurisdictions
State’s historical preference for rehabilitation

Miller v. Alabama (2012) and Montgomery v. Louisiana (2016): U.S. Supreme Court decisions recognizing youth as a mitigating factor in Eighth Amendment analysis and mandating individualized sentencing for juvenile LWOP.
People v. Hall (1976): Upheld mandatory LWOP for a 17-year-old offender; Court today distinguishes Hall as a facial challenge that did not address the as-applied scenario now before it.
People v. Poole (2025): Held that Parks applies retroactively to collateral review.

2. Legal Reasoning

The Court’s majority opinion, authored by Justice Welch, grounded its decision in Michigan’s broader constitutional protection against “cruel or unusual punishment” and the obligation to ensure proportionality. It applied the four-factor test from Lorentzen and Bullock, augmented by “evolving standards of decency” and contemporary scientific evidence on late-adolescent brain development.

Severity vs. Gravity: First-degree premeditated murder is among the most serious crimes; LWOP is the most severe penalty. However, late-adolescents serve a larger percentage of their lives in prison, and their neurological development (impulsivity, peer influence, neuroplasticity) warrants individualized consideration.
Comparisons Within Michigan: Mandatory LWOP is applied only to a narrow group of offenses (first-degree murder, certain sexual assaults of minors, and violent deaths involving explosives or adulterated drugs). Late-adolescents sentenced to LWOP will often serve longer terms than both younger (18-year-olds) and older offenders for the same crime.
Comparisons With Other Jurisdictions: Michigan remains among a minority of U.S. states that mandate LWOP for all first-degree murderers aged 18 or older. Neighboring and foreign jurisdictions (e.g., Washington State, Massachusetts, United Kingdom, Canada) have imposed individualized sentencing protections or prohibited LWOP under certain ages, reflecting evolving global standards.
Rehabilitation: Michigan has a historic preference for rehabilitative sentences. Mandatory LWOP forecloses any realistic opportunity for reform. Constitutional proportionality under article 1, § 16 demands a process to consider mitigating youth-related factors before imposing life without parole.

The Court concluded that all four factors weighed in favor of extending Parks to 19- and 20-year-olds and that the legislative rule in Hall need not be overruled because Hall did not resolve an as-applied youth challenge and remains good law for offenders aged 21 or older.

3. Impact on Future Cases and Michigan Criminal Law

Expanded Protections: All first-degree murder defendants who were under age 21 at the time of the offense will now receive the Parks-mandated individualized sentencing hearing (MCL 769.25 / 769.25a) before LWOP can be imposed.
Retroactivity: Defendants under 21, previously sentenced to mandatory LWOP, can seek collateral review and resentencing under the new rule.
Sentencing Practice: Trial courts will be required to hold “Miller hearings” for 19- and 20-year-olds, with a rebuttable presumption against LWOP that prosecutors must overcome by clear and convincing evidence, and to consider youth-related mitigation on the record.
Legislative Response: The decision may prompt legislative revisions of MCL 750.316 or the broader sentencing statutes to adjust age-based rules or to create a unified youth sentencing scheme.

Complex Concepts Simplified

Life Without Parole (LWOP): A sentence requiring an offender to spend the rest of their life in prison with no opportunity for parole.
MCL 769.25 / 769.25a (“Miller Hearings”): Statutory procedures for juvenile LWOP cases—now extended to 18–20-year-olds—requiring a hearing to consider youth-related mitigating factors before imposing LWOP.
“Cruel or Unusual Punishment” Clause: Michigan Constitution article 1, § 16 prohibits punishments that are arbitrarily harsh or out of step with societal standards and imposes a requirement of proportionality.
Four-Factor Proportionality Test: Courts must weigh (1) crime severity vs. punishment severity, (2) penalties for other Michigan crimes, (3) national and international punishment trends, and (4) state preference for rehabilitation.
Evolving Standards of Decency: A legal principle recognizing that society’s views on acceptable punishment change over time, requiring courts to examine comparative laws and scientific research.

Conclusion

The Michigan Supreme Court’s decision in People v. Taylor and People v. Czarnecki marks a significant expansion of constitutional sentencing protections for late adolescents. By extending Parks to 19- and 20-year-olds, the Court reaffirms Michigan’s commitment to proportionality, rehabilitative ideals, and evolving standards of decency. Mandatory LWOP without an individualized assessment of youth-related factors now violates article 1, § 16 when applied to this class of defendants. The ruling will reshape sentencing practice, ensure retroactive relief for eligible inmates, and likely spur legislative reconsideration of age-based sentencing rules. This decision underscores the Court’s role in enforcing deep-rooted constitutional principles, even when they challenge longstanding legislative schemes.