Last week, the Michigan Supreme Court held that imposition of mandatory life sentences for individuals under 19 and 20-years-old years old at the time of their offense violates the Michigan state constitution. See People v. Taylor, No. 166428, 2025 WL 1085247, at *1 (Mich. Apr. 10, 2025).
The majority opinion in Taylor starts like this:
Following separate and unrelated jury trials, defendants were each convicted of first-degree murder. Defendant Andrew Czarnecki was 19 years old at the time of his offense, while defendant Montario Taylor was 20 years old at the time of his. Each defendant was sentenced to a legislatively mandated punishment of life in prison without the possibility of parole (LWOP). Defendants argue that the mandatory nature of their sentences violates Michigan's prohibition against “cruel or unusual punishment,” Const. 1963, art. 1, § 16, and they ask us to extend our decision in People v Parks, 510 Mich. 225, 268, 987 N.W.2d 161 (2022), where we held that, under our state Constitution, mandatory LWOP sentences are cruel or unusual when applied to 18-year-olds.
We agree with defendants and extend Parks to individuals who were 19 or 20 years old at the time of the crime for which they were convicted. Our Constitution and caselaw interpreting it requires us to evaluate the proportionality of defendants’ sentences. To do so, we use the factors laid out in People v Lorentzen, 387 Mich. 167, 194 N.W.2d 827 (1972), and People v Bullock, 440 Mich. 15, 485 N.W.2d 866 (1992), which incorporate evolving standards of decency that mark the progress of a civilized society. Late adolescents who are 19 or 20 years old, as a class, share with 18-year-olds the same mitigating characteristics of late-adolescent brain development. The same considerations that were discussed at length in Parks apply equally to this class of late adolescents. Accordingly, as applied to defendants who were 19 or 20 years old at the time of their crime, a mandatory LWOP sentence that does not allow for consideration of the mitigating factors of youth or the potential for rehabilitation is a grossly disproportionate punishment in violation of Const. 1963, art. 1, § 16. Czarnecki and Taylor are, therefore, entitled to be resentenced in the manner set forth in MCL 769.25 and our relevant caselaw.
The Michigan Court’s decision expressly applies to all cases on direct review and “retroactively to cases on collateral review.” This important decision will require resentencing hearings for approximately 580 individuals, according to local news reporting.