Michigan Supreme Court Finds Mandatory Life Without Parole Sentences for People Under 21 Years Old Unconstitutional
Michigan’s Supreme Court held that mandatorily sentencing 19- and 20-year-old emerging adults to life without parole (LWOP) is unconstitutionally harsh and disproportionate punishment under the Michigan Constitution.
Related to: Sentencing Reform, State Advocacy
[Washington, D.C.] – Today, Michigan’s Supreme Court held that mandatorily sentencing 19- and 20-year-old emerging adults to life without parole (LWOP) is unconstitutionally harsh and disproportionate punishment under the Michigan Constitution. The ruling will apply retroactively to people currently serving such sentences in Michigan, granting them an opportunity to be resentenced, as well as changing sentencing practices in future cases.
“We applaud this decision by the Michigan Supreme Court. A wealth of brain science research makes clear that emerging adults are akin to teenagers under 18 – more impulsive, more easily influenced by peers, and also capable of remarkable growth and rehabilitation, said Liz Komar, Sentencing Reform Counsel at The Sentencing Project. “Young people are especially deserving of second chances and individualized sentencing. This decision reflects a growing national movement recognizing that emerging adults deserve special sentencing consideration, and we hope that it will serve as a model to other states.”
The decision cited research from The Sentencing Project that illustrates that people grow out of crime as they age, further reinforcing the need for sentencing reform that reflects the human capacity for growth.
In 2022, in People v. Parks, the Michigan Supreme Court held that mandatory LWOP sentences for 18-year-olds violate the Michigan Constitution’s prohibition on cruel or unusual punishments, extending the U.S. Supreme Court’s holding that such sentences for those under the age of 18 are unconstitutional. On April 1, 2025, in People v. Poole, the Michigan Supreme Court extended this protection retroactively to give people already serving such sentences the opportunity to seek resentencing. With People v. Taylor and People v. Czarnecki, the Michigan Supreme Court expanded these protections further – finding that 19- and 20-years olds are entitled to the same individualized sentencing considerations as 18-year olds under the Michigan State Constitution.
The Sentencing Project joined the Juvenile Law Center and the Michigan ACLU to support this critical progress in youth justice, by filing amicus briefs in People v. Poole, People v. Taylor, and People v. Czarnecki.
Michigan joins Washington State in banning mandatory LWOP sentences for people under age 21. The Massachusetts Supreme Court has categorically banned LWOP sentences for this age group.
