People v. Stovall

MICH. CONST. ART. I, § 16 (“cruel or unusual punishment shall not be inflicted”)

While in People v. Parks, the Michigan Supreme Court considered whether the state constitution bans mandatory life without parole sentences for 18 year olds, in Stovall the court considered whether the state ban on cruel or unusual punishment bars all life sentences, including those with the possibility of parole, for youth convicted of second degree murder.

A sentence of life in prison with the possibility of parole for a defendant who committed second-degree murder while a juvenile constitutes cruel or unusual punishment and therefore violates Const 1963, art 1, § 16.

First, the court explained that youth convicted of first-degree murder benefit from significantly more procedural safeguards during sentencing compared to those convicted of second-degree murder. The disparity in procedural safeguards often translates to juveniles convicted of second-degree murder serving harsher sentences than juveniles convicted of first-degree murder. “As a practical matter, a parolable life sentence for second-degree murder is often more severe than the minimum sentences now given to most juveniles who commit first-degree murder: 25 to 40 years.” In other words, second-degree murder yields disproportionate sentences when compared to other more serious offenses.

The court also noted the national trend toward treating juveniles as a class less harshly than adults, a key factor under the Bullock proportionality test, which requires sentencing courts to consider how the offense is punished in other jurisdictions. Finally, the court discussed how counterintuitive even parole-eligible life sentences are to rehabilitation. Not only are parole-eligible incarcerated people given a lower priority for educational and rehabilitative programming, they may not have a meaningful opportunity for release for decades, which undercuts the constitutionally-mandated goal of rehabilitation.