By Ben Solis
Gongwer News Service
The 2022 ruling from the Michigan Supreme Court barring automatic life sentences for those 18 and younger applies retroactively, the high court unanimously ruled Tuesday.
The opinion, written by Justice Richard Bernstein in People v. Poole (MSC Docket No. 166813), further establishes the bounds of how judges can sentences those 18 and under to life sentences without parole and the standard set in the 2022 decision for People v. Parks.
Bernstein ruled that the Court of Appeals was correct when it held that Parks retroactively applied to the circumstances in Poole and remanded the case to the Wayne Circuit Court with orders for a new trial.
Maya Menlo with the Michigan State Appellate Defender Office, the attorney for the defendant, John Poole, issued a statement praising the decision.
"Eighteen-year-olds are less culpable and more amenable to rehabilitation than adults whose brains are fully developed," Menlo said. "Mr. Poole and others like him deserve an opportunity to return to the community."
Parks found automatic life without parole sentences cannot be imposed without a sentencing judge first considering the mitigating characteristics of youth, or more specifically, the development of the late-adolescent brain.
The ruling was controversial as it extended the age at which a defendant could be considered fully aware of the consequences of their actions, moving it to 19 years old. Those who were 18 and younger at the time of a heinous crime like murder can still be sentenced to life sentences without parole but are now entitled to the full protections that exist within individualized sentencing procedures prior to that determination. Life without parole cannot be automatic under Parks.
The Parks decision expanded, for Michigan, upon the landmark Miller v. Alabama case, in which the U.S. Supreme Court ruled that automatic life sentences without possibility of parole for those 17 and under were unconstitutional cruel and unusual punishment.
Poole was convicted of first-degree murder for a crime he committed when he was 18 years old. His case and Parks arrived at the Supreme Court together in 2022. After the court ruled in Parks that those 18 and younger cannot be sentenced to automatic life in prison without possibility of parole, it also ruled the lower courts erred in Poole by dismissing the case on the basis that a change in law was not retroactive.
The Supreme Court asked the Court of Appeals to consider the retroactivity question, and the appellate court ruled Parks should apply retroactively and vacated Poole's sentence. Prosecutors appealed to the Supreme Court.
During oral arguments in the case held in January, Menlo said Parks' main effect was it announced a substantive new court rule, and therefore, that rule should apply retroactively to all people who are serving mandatory life sentences without the possibility of parole for offenses they committed with they were 18 years old (See Gongwer Michigan Report, January 22, 2025).
Bernstein and his colleagues agreed, and the entire bench ruled that the Court of Appeals was correct.
Bernstein said the bench looked at the Miller precedent. Under that same analysis, the bench found those same dynamics applied to Parks.
From there, Bernstein said the bench viewed other precedential test factors on state retroactivity to confirm whether the application of retroactivity was appropriate. By doing so, Bernstein said the bench held that the application was appropriate and overruled a separate analysis in Carp, particularly its "mistaken holding that the first factor focuses on whether a rule is concerned with a defendant's guilt or innocence."
Bernstein said the Court of Appeals holding – which vacated Poole's sentence of mandatory life without the possibility of parole – must be affirmed and the case must be remanded for resentencing.
Justice Kimberly Thomas did not participate in oral arguments or the opinion released Tuesday because of her prior involvement in the case.
Gongwer News Service
The 2022 ruling from the Michigan Supreme Court barring automatic life sentences for those 18 and younger applies retroactively, the high court unanimously ruled Tuesday.
The opinion, written by Justice Richard Bernstein in People v. Poole (MSC Docket No. 166813), further establishes the bounds of how judges can sentences those 18 and under to life sentences without parole and the standard set in the 2022 decision for People v. Parks.
Bernstein ruled that the Court of Appeals was correct when it held that Parks retroactively applied to the circumstances in Poole and remanded the case to the Wayne Circuit Court with orders for a new trial.
Maya Menlo with the Michigan State Appellate Defender Office, the attorney for the defendant, John Poole, issued a statement praising the decision.
"Eighteen-year-olds are less culpable and more amenable to rehabilitation than adults whose brains are fully developed," Menlo said. "Mr. Poole and others like him deserve an opportunity to return to the community."
Parks found automatic life without parole sentences cannot be imposed without a sentencing judge first considering the mitigating characteristics of youth, or more specifically, the development of the late-adolescent brain.
The ruling was controversial as it extended the age at which a defendant could be considered fully aware of the consequences of their actions, moving it to 19 years old. Those who were 18 and younger at the time of a heinous crime like murder can still be sentenced to life sentences without parole but are now entitled to the full protections that exist within individualized sentencing procedures prior to that determination. Life without parole cannot be automatic under Parks.
The Parks decision expanded, for Michigan, upon the landmark Miller v. Alabama case, in which the U.S. Supreme Court ruled that automatic life sentences without possibility of parole for those 17 and under were unconstitutional cruel and unusual punishment.
Poole was convicted of first-degree murder for a crime he committed when he was 18 years old. His case and Parks arrived at the Supreme Court together in 2022. After the court ruled in Parks that those 18 and younger cannot be sentenced to automatic life in prison without possibility of parole, it also ruled the lower courts erred in Poole by dismissing the case on the basis that a change in law was not retroactive.
The Supreme Court asked the Court of Appeals to consider the retroactivity question, and the appellate court ruled Parks should apply retroactively and vacated Poole's sentence. Prosecutors appealed to the Supreme Court.
During oral arguments in the case held in January, Menlo said Parks' main effect was it announced a substantive new court rule, and therefore, that rule should apply retroactively to all people who are serving mandatory life sentences without the possibility of parole for offenses they committed with they were 18 years old (See Gongwer Michigan Report, January 22, 2025).
Bernstein and his colleagues agreed, and the entire bench ruled that the Court of Appeals was correct.
Bernstein said the bench looked at the Miller precedent. Under that same analysis, the bench found those same dynamics applied to Parks.
From there, Bernstein said the bench viewed other precedential test factors on state retroactivity to confirm whether the application of retroactivity was appropriate. By doing so, Bernstein said the bench held that the application was appropriate and overruled a separate analysis in Carp, particularly its "mistaken holding that the first factor focuses on whether a rule is concerned with a defendant's guilt or innocence."
Bernstein said the Court of Appeals holding – which vacated Poole's sentence of mandatory life without the possibility of parole – must be affirmed and the case must be remanded for resentencing.
Justice Kimberly Thomas did not participate in oral arguments or the opinion released Tuesday because of her prior involvement in the case.
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