Sentencing; Life without parole (LWOP); Whether the holding in Miller v Alabama applies to 19-year-old offenders in light of People v Parks; Principle that mandatory LWOP sentences do not constitute cruel or unusual punishment; People v Hall; People v Adamowicz; Effect of binding precedent; Associated Builders & Contractors v Lansing

Declining again on remand to extend the holding in Miller to 19-year-olds, the court again affirmed defendant’s LWOP sentence. He was 19 years old when he murdered a young mother. In a prior appeal, the court considered his claim that his mandatory sentence of LWOP violated due process, the federal prohibition against cruel and unusual punishment, and the state prohibition against cruel or unusual punishment. It held that he had not shown he was entitled to relief and declined to extend the holding in Miller to 19-year-olds. The Supreme Court remanded, instructing the court to reconsider its ruling in light of Parks. On remand, the court found that the holding of Parks did not justify or permit it to ignore Hall, as a panel of the court recognized in a recent published opinion. “Although one could certainly read the analysis of Parks to reach those defendants who were 19 years of age or older when they committed murder or other serious offense and, as a result, received a mandatory LWOP sentence, lower courts are bound to follow the holdings of the Supreme Court and cannot ‘anticipatorily ignore’ binding precedent. And here, Hall remains good law, except as modified by Parks with respect to 18-year-olds. Given this, assuming arguendo that this panel applied the same proportionality analysis to defendant that the Parks majority applied to the defendant in that case, and further assuming arguendo that this panel arrived at a conclusion similar to that of the Parks majority, this panel would still be without authority to provide defendant any relief, given the binding precedent of Hall as-applied to those like defendant who committed murder when they were 19-years-old or older.” As a result, any review by the court of the proportionality of his “LWOP sentence would be an exercise in futility and obiter dictum, given our Supreme Court’s explicit recognition in Parks of the continuing viability of Hall to 19-year-olds and older.” Thus, having reconsidered its earlier opinion in light of Parks, “including the Parks majority’s express limitation of its holding to 18-year-olds,” the court again affirmed.