Michigan Juvenile Life Without Parole Resentencing Guide

A single moment of recklessness at the age of 20 and below in Michigan used to mean a lifetime behind bars. The justice system didn't care about your background, future potential, or efforts to change. And for decades, young adults who got mandatory life without parole (LWOP) were perceived as adults beyond redemption and were tried as such. 

However, courts, lawmakers, and legal communities are now confronting the reality that, unlike older adults, young adults are capable of growth, change, and rehabilitation. And thanks to the evolving Michigan law, the hope that was once unthinkable is now within reach for some. This article serves as a practical Michigan Juvenile Life Without Parole Resentencing Guide, showing how the law on young adults sentenced to LWOP has evolved over the years.

Life Sentence Convictions Before 2012

For a long time, Michigan law treated a 14-year-old convicted of first-degree murder the same as a 40-year-old. As stated in the Michigan Compiled Laws (MCL) 750.316, anyone convicted of that charge faced LWOP. This law applied to everyone without any consideration for youth. And the strict law interpretation didn't allow judges any discretion to weigh factors like family dynamics, maturity, and potential for rehabilitation. 

The system fundamentally overlooked scientific evidence that demonstrated that young adults have underdeveloped brains. And in such a state, these budding adults are more prone to impulsivity and susceptibility to influence but still have a remarkable ability to reform. However, all this harshness would begin to change. 

Convictions That Began Transforming Juvenile Offenders’ Sentencing Policies 

Miller v. Alabama (2012)

In 2012, at only 14 years old, both Evan Miller in Alabama and Kuntrell Jackson in Arkansas were convicted of murder and sentenced to LWOP. Evan Miller fought for reconsideration up to the U. S. Supreme Court. And after listening to his case, the court determined that imposing automatic LWOP on juvenile offenders under 18 years is unconstitutional. The practice was deemed a violation of the Eighth Amendment’s protection against cruel and unusual punishment. 

The Miller case ruling prompted Michigan to restructure its sentencing policies. The new approach allowed judges to give individualized and discretionary sentences to young offenders convicted of serious crimes. This is just one example of how Michigan case law for appeals continues to shape sentencing and second chances.

People v. Carp (2014) 

This case involved Raymond Carp, a 15-year-old who stood trial as an adult after being charged with first-degree murder and later got a LWOP. Here, the Michigan Supreme Court sought to determine if the U.S. Supreme Court's decision on Miller v. Alabama (2012) affected older sentences like that of Raymond Carp that were given before the mandatory sentence ruling changed. 

The court held that Miller's prohibition on mandatory LWOP on juveniles under 17 years didn't pass the Michigan's Sexton and Maxson’s or federal Teague v. Lane’s retroactivity tests. Miller's guidelines were also focused only on 17-year-olds and below which sidelined 18-year-olds. This means that Michigan 18-year-old offenders who were recently sentenced as well as those sentenced in the 2000s didn't have any legal avenue to challenge their sentences. 

Montgomery v. Louisiana (2016)

This Louisiana case is of Henry Montgomery who received a LWOP after he was found guilty of killing a deputy in 1963, at the age of 17. The U. S. Supreme Court revisited the issue of retroactivity based on the Miller case. And upon closer review, it determined that the 2012 ruling should apply to old cases too, not just new ones. The court felt the ruling went beyond just mere procedure and touched the basic rights of young people who might still be capable of change. 

Therefore, Michigan residents could now ask for a new hearing or a chance at parole, especially if they've grown and changed since their crime. However, 18-year-olds were still left out. 

People v. Parks (2022)

The Parks case is what brought hope to 18-year-old serious offenders in Michigan. This case involved Kemo Knicombi Parks who was convicted of first-degree premeditated murder of a victim in the parking lot of a convenience store. The Supreme Court of Michigan stated that sentencing 18-year-olds like Parks was unconstitutional because there are similarities in brain development between 17- and 18-year-olds. This means they can't be tried as adults as they're not fully developed yet. However, this ruling only applied to future rulings with no retroactive relief.

Why the Michigan Juvenile Life Without Parole Resentencing Guide Now Reaches Ages 18 to 20

Retroactive relief for people who committed serious crimes when they were 18 years old came just recently in April 2025, thanks to the People v. Poole (2025) case. Here, John Antonio Poole was convinced and paid by his uncle to murder the victim and was convicted of first-degree murder. Upon hearing his case in January 2024, the Michigan Court of Appeals determined that Poole and other young offenders aged 18 deserve to be resentenced regardless of when the crime took place.

The Michigan Supreme Court also reviewed the case and decided that the Parks case is a substantive rule which deals with the fairness of the punishment and which is applied retroactively. The court then sent the case back to the lower court for reevaluation and resentencing which gave him a chance for parole. 

The Poole's Ripple Effect Now Reaches 19 and 20-Year-Old Serious Offenders

In April 2025, relief was extended to 19 and 20-year-old offenders with a LWOP. The Michigan Supreme Court held that young adults who were 19 or 20 years old when they committed first-degree murder can no longer get LWOP.

Moreover, those who were sentenced years ago when they were 19 or 20 years old at the time, are now allowed to have their cases heard again and get resentenced. The court arrived at this decision after extensive analysis of the brain development of 18- to 20-year-olds. It concluded that, just like those under 18 years, they're more likely to be impulsive and reckless. However, they also possess great ability to reform and improve with time.

Plus, the court noted that people of that age range end up serving longer sentences compared to older adults convicted of the same crime. This alone is unjust and unconstitutional. The court also observed that when it comes to buying alcohol, carrying a concealed weapon, becoming a state trooper, and running for the U. S. Senate, the society puts an age restriction above 20 years. 

The legal advancement can be credited to the People v. Taylor (2025) and People v. Czarnecki (2025) case rulings. Montario Taylor (aged 20) and Andrew Czarnecki (aged 19) were charged with first-degree murder in Michigan in two completely different and unrelated cases. After getting found guilty and receiving a sentence of LWOP, they decided to appeal to the Court of Appeals. The court ruled against Taylor's arguments and held that his sentence still stands. And the same case applied to Czarnecki. 

On appeal to the Michigan Supreme Court, the court agreed with the two that receiving LWOP is quite extreme and goes against the Michigan Constitution. Among many arguments raised by the court, one was that people in Taylor's and Czarnecki’s age group struggle with self-control and decision-making because their prefrontal cortex (part of the brain responsible for decision-making) develops fully at the age of 25. 

Going forward, judges will no longer give LWOP to people aged 20 years and below. They will first conduct an individualized review and consider the young person's maturity, background, potential for change, and other crucial factors to determine their fate.

Your Next Steps: Using the Michigan Juvenile Life Without Parole Resentencing Guide to Seek a Second Chance

If you’re someone, or love someone, who made a mistake at 18, 19, or 20 years, and wants a second chance, this new legal development could be your chance at redemption. Living every day trying to grow, change, and atone isn't easy and should be recognized. The hope that maybe, just maybe, there's still a chance to come home is now real. Learn how to file for resentencing through post-conviction motion.

However, navigating the resentencing process isn't a walk in the park. You need a skilled and experienced attorney like Mark Linton to help you through this process to maximize your chances of getting freedom soon. Mark understands the heartbreak, the urgency and the complexity of resentencing. And he's helped many others like you find their way back to freedom. 

He knows the system, the stakes, and most importantly, how to fight tirelessly for your future. Your story isn't over and your future deserves a voice. Contact Mark Linton today to take your first step toward you or your loved one coming home.