Proportionality-Based Prohibition of Mandatory Life-Without-Parole for 19- and 20-Year-Old First-Degree Murder Defendants

Introduction

In People v Taylor and People v Czarnecki, the Michigan Supreme Court addressed whether the mandatory life-without-parole (LWOP) sentence for first-degree premeditated murder, imposed on defendants who were 19 and 20 years old at the time of their offenses, violates the “cruel or unusual punishment” clause of Michigan’s Constitution (Const 1963, art 1, § 16). The defendants, Montario Taylor (20 at offense) and Andrew Czarnecki (19 at offense), each received LWOP under MCL 750.316(1)(a). Following conviction and unsuccessful appeals in the lower courts, their cases were held in abeyance pending this Court’s decision in People v Parks (510 Mich 225, 2022), which struck down mandatory LWOP for 18-year-olds. The key question presented was whether the Parks holding must be extended to late adolescents aged 19 and 20.

Summary of the Judgment

In lieu of granting leave to appeal, the Court—by a 5-4 majority—held that the constitutional rationale of Parks must be extended to individuals who were 19 or 20 years old when they committed first-degree murder. The Court ruled that mandatory LWOP for these late adolescents violates the proportionality requirement derived from Const 1963, art 1, § 16, and constitutes unconstitutionally cruel punishment. As a remedy, defendants are entitled to the full protections of the individualized sentencing procedures set forth in MCL 769.25 and MCL 769.25a before a LWOP determination can be made. The new rule applies retroactively to cases on collateral review and does not disturb People v Hall (396 Mich 650, 1976) as to defendants who were at least 21 at the time of their crime.

Analysis

Precedents Cited

The Court relied on a sequence of federal and state precedents:

Roper v Simmons (543 US 551, 2005) – Abolished the juvenile death penalty.
Graham v Florida (560 US 48, 2010) – Prohibited LWOP for juvenile non-homicide offenses.
Miller v Alabama (567 US 460, 2012) – Banned mandatory LWOP for juveniles.
Montgomery v Louisiana (577 US 190, 2016) – Made Miller retroactive.
People v Lorentzen (387 Mich 167, 1972) and People v Bullock (440 Mich 15, 1992) – Articulated Michigan’s four-factor proportionality test under Const 1963, art 1, § 16.
People v Parks (510 Mich 225, 2022) – Held that mandatory LWOP for 18-year-olds is unconstitutional and requires an individualized sentencing hearing under MCL 769.25.
People v Boykin (510 Mich 171, 2022) – Clarified the procedures and burdens at a Miller hearing under state law.
People v Hall (396 Mich 650, 1976) – Upheld mandatory LWOP for felony murder committed by a minor (17-year-old) before the advent of Miller and Parks; left intact for as-applied challenges to older offenders.

Legal Reasoning

The majority’s legal analysis unfolded in four steps:

Constitutional Text and Standard: Article 1, § 16 of Michigan’s Constitution forbids “cruel or unusual punishment” and demands proportionality. Michigan’s protection is broader than the Eighth Amendment.
Four-Factor Proportionality Test: Reaffirming Lorentzen and Bullock, the Court evaluated:
- (1) Severity of the punishment vs. gravity of the offense;
- (2) Penalties for other offenses in Michigan;
- (3) Penalties in other jurisdictions for the same offense;
- (4) Michigan’s goal of rehabilitation.
All four factors were found to support an individualized procedure before LWOP for those aged 19 and 20.
Scientific and Social-Science Evidence: The Court considered unrebutted research showing that late adolescents share juvenile-like brain characteristics—heightened impulsivity, peer pressure susceptibility, and continued neuroplasticity up to about age 25—undermining full culpability and increasing prospects for rehabilitation.
Comparative Law and Rights Milestones: Michigan and most states do not recognize full adult legal status until age 21 (e.g., alcohol purchase, concealed-carry licenses, election eligibility). Nationwide, only a minority of jurisdictions mandate LWOP for first-degree murder, and some foreign systems prohibit LWOP under age 21.

Based on these findings, the Court held that mandatory LWOP for offenders aged 19 or 20 constitutes grossly disproportionate and cruel punishment under Michigan’s Constitution. As in Parks, the remedy is to extend the Miller-Parks individualized sentencing procedures (MCL 769.25 / MCL 769.25a) with a rebuttable presumption against LWOP and a clear-and-convincing burden on the prosecutor.

Impact

This decision will have immediate and far-reaching consequences:

Circuit courts must vacate and re-resolve LWOP sentences for defendants who were 19 or 20 at the time of first-degree murder.
Defendants serve as part of a presumptive class entitled to individualized “Miller hearings” before LWOP can be reimposed.
The extension is retroactive on collateral review, potentially affecting dozens of cases.
The legal bright line for mandatory LWOP remains at age 21, preserving Hall for offenders aged 21 or older while inviting legislative or future judicial reevaluation of that threshold.

Complex Concepts Simplified

Mandatory LWOP: A life sentence with no possibility of parole, automatically imposed by statute for certain offenses.
Const 1963, art 1, § 16: Michigan’s state constitutional provision banning “cruel or unusual punishment” and requiring proportionality in sentencing.
Four-Factor Test: Courts must weigh (1) offense gravity vs. punishment severity, (2) other state penalties, (3) out-of-state penalties, and (4) the goal of rehabilitation.
MCL 769.25 / 769.25a (“Miller hearings”): Statutory procedures requiring an individualized sentencing hearing and a presumption against LWOP when youth is at issue; the prosecutor must prove by clear and convincing evidence that LWOP is appropriate.
Neuroplasticity and Late-Adolescent Brain: Scientific studies show that the human brain continues to develop into the mid-20s, affecting decision-making, risk assessment, and susceptibility to peer influence.
Evolving Standards of Decency: A constitutional principle that, over time, society’s moral progress can render once-accepted punishments “cruel or unusual.”

Conclusion

By extending Parks to 19- and 20-year-old offenders, the Michigan Supreme Court has reinforced the principle that severe, mandatory penalties must account for the diminished culpability and enhanced rehabilitative prospects of late adolescents. This ruling underscores Michigan’s broader constitutional protection against cruel or unusual punishment, mandates individualized sentencing procedures for a newly recognized class, and maintains a bright-line at age 21 for mandatory LWOP. The decision marks a significant development in juvenile and adolescent sentencing jurisprudence and calls on the Legislature and lower courts to implement these constitutional safeguards.