By Lily Guiney
Gongwer News Service
A murder case adjudicated in 1988 was remanded for resentencing in a Tuesday opinion from the Michigan Court of Appeals, which found the sentencing court did not take the defendant’s youth into proper account as a mitigating factor.
People v. Campbell (COA Docket No. 368742) saw defendant Cameron Campbell sentenced to concurrent prison terms of 65 to 100 years for each of two counts of second-degree murder convictions and an assault with intent to murder conviction. Campbell was 18 at the time of the murders, which is the basis of his current argument for appeal.
In an opinion authored by Judge Sima Patel and signed by Judge Kathleen Feeney, the court agreed with Campbell’s assertion that the concurrent prison terms, which allow for the possibility of parole but still constitute a life sentence, violate the principal of proportionality which courts must maintain when weighing sentences against the crimes for which a defendant is convicted.
Judge Kirsten Frank Kelly concurred in short separate opinion that simply cited various case law involving lengthy sentences for minors or young adults.
The main reasons the majority agreed to order Campbell’s resentencing are the changes in case law and statute since the time of the initial sentence which have placed further burdens on courts to consider a defendant’s age if they are a minor or 18 years old at the time of a crime.
“We find no error warranting reversal of defendant’s convictions. But we conclude that the recent evolution of the law regarding juvenile and 18-year-old offenders has rendered defendant’s term-of-years sentences of 65 to 100 years’ imprisonment for his convictions invalid under the principle of proportionality because the sentencing court failed to consider defendant’s youth and its attendant characteristics as mitigating factors,” the opinion said. “For the reasons stated in this opinion, we affirm in part and reverse in part the trial court order denying defendant’s motion for relief from judgment, vacate defendant’s sentences for second-degree murder and AWIM, and remand for resentencing.”
The judges compared the sentence given to Campbell to defendants of his age who were convicted of first-degree murder in landmark cases and found that Campbell’s was “more severe than generally authorized for offenders who were juveniles or between 18 and 20 years old when they committed first-degree murder.”
“The default sentence for such offenders is now a minimum term of 25 to 40 years’ imprisonment with a maximum of at least 60 years’ imprisonment if the court decides not to sentence the defendant to life without parole,” the opinion said. “Defendant was entitled to be sentenced in a manner that duly accounted for the individualized circumstances of defendant and the offenses, which included his ‘youth and its attendant characteristics as potentially mitigating factors.’”
Although much of the legal reform in favor of accounting for a defendant’s age occurred after 1988, the court’s own ruling in People v. Eads earlier this year set the precedent for applying case law such as Miller v. Alabama, in which the U.S. Supreme Court ruled life without parole for minors to be unconstitutional, even when the crime in question occurred before the precedent existed.
“The fact that (a defendant’s) direct appeal occurred well before Miller and its progeny came into being is enough in itself to establish good cause under MCR 6.508(D)(3)(a) for failing to raise the challenge at that time,” the court wrote in its January 2025 Eads opinion.
The court rejected Campbell’s arguments that his rights were violated during trial due to certain evidence being redacted, alleged prosecutorial misconduct and inadequate trial defense, dismissing his appeal of the convictions.
Gongwer News Service
A murder case adjudicated in 1988 was remanded for resentencing in a Tuesday opinion from the Michigan Court of Appeals, which found the sentencing court did not take the defendant’s youth into proper account as a mitigating factor.
People v. Campbell (COA Docket No. 368742) saw defendant Cameron Campbell sentenced to concurrent prison terms of 65 to 100 years for each of two counts of second-degree murder convictions and an assault with intent to murder conviction. Campbell was 18 at the time of the murders, which is the basis of his current argument for appeal.
In an opinion authored by Judge Sima Patel and signed by Judge Kathleen Feeney, the court agreed with Campbell’s assertion that the concurrent prison terms, which allow for the possibility of parole but still constitute a life sentence, violate the principal of proportionality which courts must maintain when weighing sentences against the crimes for which a defendant is convicted.
Judge Kirsten Frank Kelly concurred in short separate opinion that simply cited various case law involving lengthy sentences for minors or young adults.
The main reasons the majority agreed to order Campbell’s resentencing are the changes in case law and statute since the time of the initial sentence which have placed further burdens on courts to consider a defendant’s age if they are a minor or 18 years old at the time of a crime.
“We find no error warranting reversal of defendant’s convictions. But we conclude that the recent evolution of the law regarding juvenile and 18-year-old offenders has rendered defendant’s term-of-years sentences of 65 to 100 years’ imprisonment for his convictions invalid under the principle of proportionality because the sentencing court failed to consider defendant’s youth and its attendant characteristics as mitigating factors,” the opinion said. “For the reasons stated in this opinion, we affirm in part and reverse in part the trial court order denying defendant’s motion for relief from judgment, vacate defendant’s sentences for second-degree murder and AWIM, and remand for resentencing.”
The judges compared the sentence given to Campbell to defendants of his age who were convicted of first-degree murder in landmark cases and found that Campbell’s was “more severe than generally authorized for offenders who were juveniles or between 18 and 20 years old when they committed first-degree murder.”
“The default sentence for such offenders is now a minimum term of 25 to 40 years’ imprisonment with a maximum of at least 60 years’ imprisonment if the court decides not to sentence the defendant to life without parole,” the opinion said. “Defendant was entitled to be sentenced in a manner that duly accounted for the individualized circumstances of defendant and the offenses, which included his ‘youth and its attendant characteristics as potentially mitigating factors.’”
Although much of the legal reform in favor of accounting for a defendant’s age occurred after 1988, the court’s own ruling in People v. Eads earlier this year set the precedent for applying case law such as Miller v. Alabama, in which the U.S. Supreme Court ruled life without parole for minors to be unconstitutional, even when the crime in question occurred before the precedent existed.
“The fact that (a defendant’s) direct appeal occurred well before Miller and its progeny came into being is enough in itself to establish good cause under MCR 6.508(D)(3)(a) for failing to raise the challenge at that time,” the court wrote in its January 2025 Eads opinion.
The court rejected Campbell’s arguments that his rights were violated during trial due to certain evidence being redacted, alleged prosecutorial misconduct and inadequate trial defense, dismissing his appeal of the convictions.
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