Sentencing; Juvenile resentencing; MCL 769.25a; People v Boykin; Youth as a mitigating factor; People v. Snow factors; People v Copeland; Proportionality; Term-of-years sentence; People v Steanhouse; Underlying offense; Miller v Alabama factors; People v Taylor

The court held that the trial court properly considered defendant’s youth as a mitigating factor and did not abuse its discretion by imposing a 40-to-60-year term-of-years sentence for his juvenile felony-murder conviction. Defendant was convicted of murdering his girlfriend’s two-year-old child and, after earlier proceedings, was resentenced under MCL 769.25a after the prosecution stipulated to a term-of-years sentence. The trial court imposed the maximum term permitted by statute. On appeal, the court held that when resentencing a juvenile defendant to a term-of-years sentence under MCL 769.25a, the trial court need only make a record showing that it considered youth and treated it as mitigating. The court found that requirement satisfied because the trial court considered juvenile brain development, defendant’s trauma and abuse history, his educational and mental-health background, and his rehabilitation in prison. The court next held that the sentence was proportionate despite those mitigating factors because the trial court was required to consider the seriousness of the offense and described the murder as “one of the most gruesome, disturbing murders” it had handled and “the most egregious murder” it had seen involving what was inflicted on an innocent two-year-old child. The court further held that considering the underlying offense did not improperly treat a Miller factor as aggravating because Miller-factor analysis was not required for a term-of-years sentence. Affirmed.