Sentencing; Miller v Alabama; People v Parks; Binding precedent limitations as to crimes committed before the age of 19; Life without the possibility of parole (LWOP)

The court concluded that because binding precedent limits the application of the Miller and Parks “decisions to crimes committed before the age of 19,” it must affirm defendant’s sentence. He was convicted of first-degree murder and sentenced to serve a prison term of LWOP. At the time he committed that offense, he was 19 years old. Defendant cited Miller and Parks in asking the court “to rule that he was improperly sentenced to [LWOP] for the crime he committed at the age of 19.” The court held that without “additional extension of Miller by the United States Supreme Court or Parks by our Supreme Court, we must conclude that defendant’s mandatory prison sentence of [LWOP] for first-degree felony murder committed at the age of 19 continues to pass muster under the United States Constitution and the Michigan Constitution . . . . ”