Entitlement to relief from judgment under MCR 6.508(D); Sentencing; Whether imposing a mandatory life sentence without the possibility of parole (LWOP) on a 19-year-old offender violates the Michigan Constitution’s prohibition on cruel or unusual punishment; People v Parks; People v Stovall; People v Adamowicz (On Second Remand); People v Hall; People v Czarnecki (On Remand, On Reconsideration)

Concluding that defendant’s mandatory prison sentence of LWOP “for first-degree murder committed at age 19 does not violate our Constitution’s prohibition on cruel or unusual punishment,” the court affirmed. He was convicted of first-degree premeditated murder, first-degree felony murder, and felony-firearm. “He was 19 years old at the time of the offense.” At sentencing, the trial court vacated his “conviction of first-degree felony murder and sentenced him to mandatory [LWOP] for premeditated murder with a consecutive sentence of two years” for felony-firearm. Although he “satisfied the procedural requirements of MCR 6.502(G), binding precedent from our Supreme Court and this Court precludes us from finding that he is entitled to relief from judgment under MCR 6.508(D).” He argued that his sentence was invalid because imposing a mandatory LWOP sentence “on a 19-year-old offender violates the Michigan Constitution’s prohibition on cruel or unusual punishment.” The Supreme Court directed the court to consider this issue in light of Parks and Stovall. In Parks, the “Supreme Court held that 'mandatorily subjecting 18-year-old defendants convicted of first degree murder to a sentence of [LWOP] violates the principle of proportionality derived from the Michigan Constitution . . . and thus constitutes unconstitutionally cruel punishment under Const. 1963, art. 1, § 16.'” Subsequently, two panels of the court “held in binding, published opinions that the holding in Parks does not extend to offenders who are over 18 years old.” In Adamowicz it held that imposing a mandatory LWOP sentence “for first-degree murder on a defendant who was 21 years old at the time of the offense did not violate our Constitution’s prohibition on cruel or unusual punishment.” The court reasoned that, in Hall, the “Supreme Court ‘already upheld the constitutionality of a sentence of [LWOP] imposed upon an adult for the crime of first-degree murder.’” The court held “that it was bound by Hall because it had not been reversed or modified since its issuance, and because ‘the Parks Court conceded that it was not altering the holding in Hall to the extent it applied to defendants over the age of 18.’” A few months later, in Czarnecki, the court “declined to extend the holding in Parks to a 19-year-old offender who was sentenced to mandatory [LWOP] for first degree murder.” It explained it was not bound by “Adamowicz because that case involved a 21-year-old offender.” However, it concluded, as “in Adamowicz, that it was bound by Hall to uphold the constitutionality of the sentence because the defendant was over 18 years old.” The court was bound by this authority.