Sentencing for a first-degree felony murder committed when defendant was 19 years old; Mandatory life without parole (LWOP); People v Parks; Applicability of Parks to 19-year-old offenders; People v Czarnecki; People v Hall

On remand from the Supreme Court to reconsider, in light of Parks, defendant’s constitutional challenge to his mandatory LWOP sentence for a first-degree felony murder committed when he was 19, the court again affirmed his sentence. He was also convicted of armed robbery, conspiracy to commit armed robbery, CCW, and felony-firearm. The court recently considered the issue of the applicability of Parks to 19-year-old offenders in Czarnecki. In that case, the court noted the Supreme Court in Hall “upheld the constitutionality of a sentence of life without parole for a defendant convicted of felony murder, expressly rejecting the defendant’s argument that such a sentence constitutes cruel or unusual punishment under’” the Michigan Constitution. The court further noted in Czarnecki that the “Supreme Court in Parks explicitly limited the effect its opinion had on Hall, stating that its ‘opinion today does not affect Hall’s holding as to those older than 18.’” As a result, the court concluded in Czarnecki that “it follows that Hall’s holding continues to apply to those older than 18.” The court rejected defendant’s argument here for the reasons stated in Czarnecki.