Sentencing of juveniles for first-degree murder; Consideration of the distinctive attributes of youth; Miller v. Alabama; People v. Meadows; Montgomery v. Louisiana; People v. Wines; People v. Snow; Individualized sentencing; People v. Steanhouse; People v. Milbourn; Consideration of updated information at resentencing; People v. Triplett

The court held that the trial court did not abuse its discretion in considering the attributes of youth in resentencing defendant for a first-degree premeditated murder committed when she was a juvenile, but rather, thoughtfully balanced “the circumstances surrounding the offender—both at the time of the offense and in the years since—and the offense.” She was originally sentenced to a mandatory life sentence without the possibility of parole. Almost a decade later, the U.S. Supreme Court decided Miller, ruling that “mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on cruel and unusual punishments.” In response, the Michigan “Legislature enacted MCL 769.25 and MCL 769.25a, which address life-without-parole offenses committed by minors and the option of imprisonment for a term of years.” Defendant claimed that the trial court failed to “adequately consider the distinctive attributes of youth, and that, in light of the many factors attributable to defendant’s status as a minor at the time of the murder, the resentencing judge should have been more lenient.” She specifically argued that “the resentencing judge placed too much emphasis on the statements contained in defendant’s allocution at resentencing rather than on the attributes and characteristics of youth.” However, the court noted that, while Wines “requires the trial court to ‘take into account the attributes of youth,’ it does not require the trial court to consider youthful attributes in a vacuum as a blanket award of leniency.” The court further noted that “a trial court is required to consider updated information at resentencing.” On the record here, it could not hold that “the trial court failed to consider the attributes of youth when sentencing defendant, or abused its discretion by failing to afford them adequate weight. Rather, the trial court did consider the attributes of youth but found that these attributes were not the basis for the crime and therefore did not warrant leniency during resentencing.” And where, as in this case, the offender did “not display the typical attributes of youth, the trial court is not required to treat the offense as a product of youth. More importantly,” the court agreed with the trial court that her “failure to express any remorse for her crime at the resentencing hearing indicated that her crime was not a product of any youthful characteristics; rather, the crime was an expression of innate character flaws which transcended defendant’s youth.”