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State Supreme Court rules life with parole for juveniles who commit 2nd-degree murder violates MI Constitution

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Posted at 2:48 PM, Jul 28, 2022
and last updated 2022-07-28 14:48:42-04

LANSING, Mich.  — The Michigan Supreme Court has ruled that a sentence of life in prison with the possibility of parole for a juvenile who committed second-degree murder violates Michigan’s constitution.

The ruling comes after the justices heard arguments related to the sentencing of Montez Stovall.

In 1991, Stovall shot and killed two men. He was 17 years old at the time. In 1992, Stovall pleaded guilty in Wayne County to second-degree murder and possession of a firearm during the commission of a crime in exchange for the dismissal of first-degree murder charges.

Stovall was sentenced to life in prison with the possibility of parole.

In 1993, Stovall moved to withdraw his plea, but the trial court denied the motion.

Stovall continued to file motions for relief of judgment, saying his plea was illusory and that his sentences violated the Eighth Amendment of the United States Constitution because his sentences effectively denied him a meaningful opportunity for release.

The Michigan Supreme Court heard arguments in the case in March 2022.

Justices looked at whether the defendant’s parolable life sentences for second-degree murder were the result of an illusory plea bargain and whether the defendant’s sentences violated the prohibition against “cruel and unusual punishments” found in the Eighth Amendment to the United States Constitution, and/or the prohibition against “cruel or unusual punishment” found in Michigan’s Constitution, where he was under the age of 18 at the time of the offenses.

An illusory plea bargain is one in which the defendant receives no benefit from the agreement.

The court ruled that Stovall’s plea wasn’t illusory because he could have been sentenced to life in prison without parole if he had been convicted of first-degree murder.

Justices determined Stovall’s challenge to his parolable life sentence under the Eighth Amendment also failed because his sentence included the possibility of parole. However, the Michigan Constitution does forbid unusually excessive imprisonment. A parolable life sentence is the most severe punishment that can be imposed for second-degree murder.

The Michigan Supreme Court ultimately decided that a parolable life sentence for a defendant who commits second-degree murder while a juvenile violates Article 1, § 16 of the Michigan Constitution.

The Michigan Supreme Court vacated Stovall’s sentence for second-degree murder and remanded the case to the Wayne Circuit Court.

Read the full opinion from the Michigan Supreme Court below:

Stovall Opinion by WXMI on Scribd

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