Michigan's convicts serving life sentences for crimes committed as juveniles won't be getting resentenced or a chance for parole after a Michigan Supreme Court ruling on Monday.
The state's highest court determined in a 4-3 decision that more than 350 juvenile "lifers" who are serving sentences related to killings committed at age 17 and younger should not be retroactively resentenced, reports MLive.com. This case was in response to a 2012 U.S. Supreme Court ruling that held it was unconstitutional to generally punish teens to life without the possibility of parole.
Why were these juvenile lifers denied a chance at parole?
Cruel and Unusual Juvenile Sentencing
The U.S. Supreme Court determined in June 2012, in a case called Miller v. Alabama, that mandatory life sentences without parole for juvenile offenders violated the Eighth Amendment. While the ruling didn't prevent all juvenile offenders from receiving life without parole for homicide offenses, it ruled that mandatory sentencing for juveniles could not include life without parole.
The nation's highest court has greatly increased protections for juvenile offenders in the last decade. In Graham v. Florida, the Court struck down life without parole sentences for juveniles who are convicted of non-homicide crimes. Many of these decisions have been driven by the reasoning that teens' brains haven't fully formed at the time of their crimes. Since they lack the real capacity that adult convicts have, like the mentally disabled, some forms of punishment are simply inappropriate.
Mich. Denies Retroactive Effect
Since the Miller decision, state courts have been grappling with how to deal with juvenile "lifers" who were sentenced prior to the 2012 decision.
For example, Massachusetts' Supreme Court ruled that courts could not impose life without parole on juvenile offenders, comparing a teenager's life sentence to the death penalty. Other states changed their sentencing laws to be in line with the Miller decision, with many giving juvenile "lifers" a parole hearing after 25 years served.
Michigan's Supreme Court, however, felt that resentencing these offenders would be too difficult for many convicts. The court felt that because many of these offenses occurred more than 20 years ago, collecting evidence and witnesses for aggravating and/or mitigating circumstances would be extremely limited.
The U.S. Supreme Court did not address retroactivity in its Miller decision, but the issue is now working its way through federal courts.
- Michigan Supreme Court: Not so fast on resentencing juvenile lifers (Detroit Free Press)
- Legal to Sentence Juvenile to Death Penalty? (FindLaw's Blotter)
- Graham Applies Retroactively; No Life Without Parole for Juvies (FindLaw's U.S. Ninth Circuit)
- When Can Juveniles Be Tried As Adults? (FindLaw's Blotter)