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153081 - People v Kenya Ali Hyatt

The People of the State of Michigan,
 
Joseph F. Sawka
 
Plaintiff-Appellant,
 
v
(Appeal from Ct of Appeals)
 
 
(Genesee – Fullerton, J.)
 
Kenya Ali Hyatt,
 
Ronald D. Ambrose
 
Defendant-Appellee.
 

Summary

These two cases concern the sentencing of juvenile offenders who have been convicted of first-degree murder under MCL 769.25. The cases will be argued together.
 
In Skinner, the 17-year-old defendant enlisted friends to kill her parents, and they succeeded in killing one of them. The defendant was convicted of first-degree premeditated murder and sentenced to mandatory life without parole. After the United States Supreme Court held in Miller v Alabama, 567 US 460; 132 S Ct 2455; 183 L Ed 2d 407 (2012), that a mandatory sentencing scheme of life in prison without the possibility of parole for juvenile offenders is unconstitutional, the Michigan Legislature enacted MCL 769.25, providing for a term of years for juveniles who commit first-degree murder (or certain other offenses), unless the prosecution files a motion seeking life without parole, and the trial court holds a hearing. In this case, following a hearing, the defendant was resentenced to life without parole, over defense objection that this decision could only be made by a jury under Apprendi v New Jersey, 530 US 466, 476; 120 S Ct 2348; 147 L Ed 2d 435 (2000), in light of Montgomery v Louisiana, 577 US ___; 136 S Ct 718; 193 L Ed 2d 599 (2016), and Miller v Alabama. In a split decision, the Court of Appeals agreed with the defendant and remanded for resentencing before a jury. This Court has granted leave to address whether the decision to sentence a juvenile to life without parole under MCL 769.25 must be made by a jury beyond a reasonable doubt. 
 
In Hyatt, the 17-year-old defendant helped family members to carry out a plan to rob a security guard of his firearm. During the robbery, the guard was fatally shot. The defendant was convicted of first-degree felony murder and, after a hearing on the prosecutor’s motion, the trial court sentenced him to life without parole under MCL 769.25. The Court of Appeals held that it was bound to follow People v Skinner, 312 Mich App 15 (2015), but declared a conflict, expressing its opinion that a jury need not make the sentencing decision. Subsequently, the Court of Appeals convened a conflict-resolution panel, which unanimously agreed that no jury is needed. However, a four-judge majority of the conflict panel nevertheless ordered resentencing, believing that the trial court had erred by failing to decide whether the defendant exhibited “irreparable corruption” so as to deserve life without parole. The conflict panel declared that sentencing courts must start with the understanding that, more likely than not, life without parole is not a proportionate sentence for a juvenile. The conflict panel also declared the appellate standard of review in these cases to be “abuse of discretion” based on the notion that sentencing a juvenile to life without parole is “inherently suspect” and probably disproportionate. This Court has directed oral argument to address whether the Court of Appeals conflict-resolution panel erred by applying a heightened standard of consideration and review for sentences imposed under MCL 769.25.