Motion for relief from judgment; Successive motion; MCR 6.502(G); MCR 6.508(D); Sentencing; Youthful offender; Second-degree murder; MCL 750.317; Proportionality; People v Milbourn; People v Stovall; People v Taylor; People v Boykin; MCR 6.429; Invalid sentence

The court held that the trial court abused its discretion by granting defendant’s successive motion for relief from judgment and ordering resentencing. Defendant was 18 when he committed second-degree murder and felony-firearm, and he received a 25-to-50-year murder sentence, which was within the guidelines range of 180 to 300 months, or life. The court first held that the trial court legally erred by failing to analyze whether defendant was entitled to relief under MCR 6.508(D). Although a retroactive change in law may satisfy the successive-motion gateway in MCR 6.502(G)(2), Stovall makes clear that this is only “a threshold for overcoming the procedural bar,” and the trial court improperly conflated that threshold with entitlement to relief. The court also held that MCR 6.429 did not independently authorize resentencing because MCR 6.429(B)(4) requires a defendant who exhausted appellate remedies to proceed under MCR 6.500 et seq. The court next held that the trial court committed factual and legal errors by misunderstanding the sentence. It erroneously treated defendant as though he had to serve 50 years before parole eligibility, while he actually received a 25-year minimum, and it relied on the maximum term even though the guidelines “prescribe only the minimum sentence ranges.” The court further held that neither Stovall nor Taylor supported relief because Stovall involved a juvenile sentenced to parolable life, and Taylor involved mandatory life without parole for 19- and 20-year-old offenders, while defendant received a term-of-years sentence with parole eligibility at age 45. Finally, the court held that defendant failed to show actual prejudice or an invalid sentence because the original sentencing judge considered defendant’s youth and juvenile record, Boykin does not require detailed on-the-record findings about youth, and the within-guidelines sentence remained presumptively proportionate. Reversed.