Case: People v. Stovall

No. 92-0334-01 | Michigan state trial court

Filed Date: June 29, 2017

Closed Date: 2022

Clearinghouse coding complete

Case Summary

This action arose from a successive motion for relief for judgment filed by the defendant in this criminal case on June 29, 2017 in Michigan state trial court (Third Circuit Court, case no. 92-0334-01). The defendant pleaded guilty in 1992 to second degree murder; the plea deal included a sentence agreement for life in prison with the possibility of parole, or parolable life.  In the motion at issue here, the defendant argued that his plea was illusory and that his sentence violated the Eighth …

This action arose from a successive motion for relief for judgment filed by the defendant in this criminal case on June 29, 2017 in Michigan state trial court (Third Circuit Court, case no. 92-0334-01). The defendant pleaded guilty in 1992 to second degree murder; the plea deal included a sentence agreement for life in prison with the possibility of parole, or parolable life.  In the motion at issue here, the defendant argued that his plea was illusory and that his sentence violated the Eighth Amendment because it denied him a meaningful opportunity for release as required under Graham and Miller.  On August 23, 2017, Judge Kelly Ramsey denied defendant's motion, holding that Miller and its progeny did not apply retroactively, that the plea was not illusory, and that the defendant had a meaningful opportunity for parole.  The court of appeals denied defendant's initial application for leave to appeal on August 23, 2018. The Michigan Supreme Court remanded the case back to the appellate court for consideration "as on leave granted" on June 19, 2019. 504 Mich. 892. On November 5, 2020, the appellate court affirmed the trial court's denial of relief. 334 Mich.App. 553.  The Michigan Supreme Court granted review on April 30, 2021, directing the parties to brief the constitutionality of defendant's sentence under the federal and state constitutions.  507 Mich. 938.  

On July 28, 2022, the Michigan Supreme Court vacated the defendant's sentence, finding that it violated the state constitutional prohibition against cruel or unusual punishment.  The court reasoned that although defendant's federal Eighth Amendment challenge to his parolable life sentence failed under Miller and subsequent U.S. Supreme Court cases, the Michigan Constitution offered broader protections, forbidding unusually excessive imprisonment. The Court cited as evidence of disproportionality the likelihood that, pursuant to the state's Miller-fix statute, a person convicted of first-degree murder committed as a child was likely to be released earlier than a person sentenced to parolable life for second-degree murder committed as a child.  The Court further cited the failure of parolable life sentences to offer the requisite meaningful opportunity for release based on demonstrated maturity and rehabilitation.  To that point, the Court noted that parolable lifers were given lower priority for educational and rehabilitative programming, as well as the susceptibility of the parole process to "the fluctuations of executive branch policies," including policies that might instruct the parole board to forgo consideration of all lifers for parole. Holding that parolable life sentences for juvenile offenders convicted of second-degree murder violated the Michigan Constitution, the Court vacated the defendant's sentence and remanded to the trial court for further proceedings.  

Summary Authors

Tessa Bialek (7/10/2023)

Documents in the Clearinghouse

Document

No. 342440

Opinion

Michigan state appellate court

Nov. 5, 2020

Nov. 5, 2020

Order/Opinion

965 N.W.2d 965

No. 162425

Order

Michigan state supreme court

April 30, 2021

April 30, 2021

Order/Opinion

957 N.W.2d 957

No. 162425

Opinion

Michigan state supreme court

July 28, 2022

July 28, 2022

Order/Opinion

987 N.W.2d 987

Resources

Docket

Last updated Aug. 30, 2023, 1:25 p.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Michigan

Case Type(s):

Criminal Justice (Other)

Special Collection(s):

Juvenile Parole

Key Dates

Filing Date: June 29, 2017

Closing Date: 2022

Case Ongoing: No

Plaintiffs

Plaintiff Description:

The defendant who initiated this action was serving a life with parole sentence for a crime committed under age 18.

Attorney Organizations:

ACLU of Michigan

Juvenile Law Center

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Case Details

Causes of Action:

42 U.S.C. § 1983

State law

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Cruel and Unusual Punishment

Special Case Type(s):

Criminal

Available Documents:

Non-settlement Outcome

Any published opinion

Outcome

Prevailing Party: Defendant

Source of Relief:

Litigation

Issues

General/Misc.:

Juveniles

Parole grant/revocation