Youth sentencing; Cruel or unusual punishment & proportionality; Miller v Alabama; People v Boykin; People v Stovall; Motion for relief from judgment (MFRJ)

The court concluded that Miller and its progeny rendered defendant-Eads’s “term-of-years sentence invalid under both the Michigan Constitution and our state’s proportionality requirement.” It held that defendant was “entitled to be resentenced in a manner that comports with this jurisprudence and duly accounts for his youth and its attendant characteristics at the time he committed the offense at issue.” Thus, the trial court’s order denying his MFRJ was reversed, his sentence for second-degree murder was vacated, and the case was remanded. Eads was convicted of second-degree murder and felony-firearm for crimes he committed as a juvenile. He was sentenced “as an adult and, departing upward from the guidelines,” consecutive terms of 50 to 75 years were imposed for second-degree murder. Overall, the court failed to see how his 50-to-75-year term-of-years sentence “could pass muster under the Michigan Constitution’s prohibition against cruel or unusual punishment, when the parolable life sentence at issue in Stovall could not.” Thus, it found his sentence was unconstitutional and he was entitled to resentencing. The court also concluded that a term of 50 to 75 years was “disproportionate to Eads and the circumstances surrounding his offense given his status as a juvenile at the time that he committed the offense and the inherent, constitutionally significant differences between juveniles and adults for purposes of sentencing.” It found the sentence was, “in purpose and effect, even more severe in some respects than the life-sentence alternative that our Supreme Court has now deemed so disproportionate as to be categorically unconstitutional for juvenile offenders such as Eads.” The court could not conclude “that such a sentence nonetheless meets our state’s proportionality requirement. Furthermore, while a trial court is not obligated to ‘give a detailed on-the-record explanation’ regarding each of the Miller factors when imposing its sentence,” it was “clear from the existing record that the court in this case did not consider Eads’s youth and its attendant characteristics as potentially mitigating factors.”