Henry Hill v. Rick Snyder, 821 F.3d 763

Background

Michigan prosecuted and convicted several individuals as adults for crimes committed under age 18; each received first-degree murder convictions carrying mandatory life sentences and statutory ineligibility for parole.
Plaintiffs sued under 42 U.S.C. § 1983 challenging Michigan statutes (Mich. Comp. Laws §§ 750.316(1), 791.234(6)) that barred parole eligibility, alleging Eighth Amendment violations.
After initial pleadings and limited dismissal, the Supreme Court decided Miller v. Alabama (2012), holding mandatory life without parole for juveniles unconstitutional because youth’s characteristics must be considered.
The district court (2013) ruled Miller applied to the plaintiffs, declared Michigan’s parole-ineligibility statute unconstitutional as applied to juvenile offenders, and entered an injunction requiring compliance with Miller for all juveniles sentenced to life.
Michigan enacted Public Act No. 22 (2014) creating §§ 769.25 and 769.25a to implement Miller procedures and to condition resentencing on a finding of Miller’s retroactivity; state appellate decision (Skinner) later struck parts of that scheme.
After the Supreme Court’s Montgomery v. Louisiana (2016) holding that Miller is retroactive, the Sixth Circuit vacated the district court’s orders and remanded for the district court to allow amendment and reconsider remedies in light of Montgomery, Miller, and the changed state law.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller applies retroactively to plaintiffs whose convictions were final before Miller	Miller applies retroactively; plaintiffs entitled to relief	Miller is not retroactive; no relief required	Montgomery establishes Miller is retroactive (court remanded to apply Montgomery)
Whether Michigan’s statute barring parole (§ 791.234(6)) is unconstitutional as applied to juvenile offenders	Statute denies meaningful parole opportunity in violation of Eighth Amendment as interpreted by Miller	State can enforce statute; relief improper or limited	District court had found statute unconstitutional; Sixth Circuit vacated and remanded for reconsideration under Montgomery and state changes
Scope of district court’s injunction—whether relief extends beyond named plaintiffs	Relief should apply to all similarly situated juvenile offenders	Relief should be limited to named plaintiffs; class treatment improper without certification	Sixth Circuit instructs district court to reconsider scope and whether class certification is required given Circuit precedent and potential mootness issues
Effect of Michigan’s 2014 legislative amendments (§§ 769.25, 769.25a) on federal claims and remedy	Legislative fix is insufficient; federal court should enforce Miller-compliant remedy	Legislative scheme (triggered by Montgomery) provides state remedy; federal claims may be moot	Sixth Circuit vacated district orders and remanded for the district court to assess the new state scheme, permit amendments, and develop the record

Key Cases Cited

Miller v. Alabama, 132 S. Ct. 2455 (holding mandatory life without parole for juveniles unconstitutional and requiring individualized youth-focused sentencing)
Montgomery v. Louisiana, 136 S. Ct. 718 (holding Miller announces a substantive, retroactive rule; states must provide relief such as parole consideration)
Roper v. Simmons, 543 U.S. 551 (recognizing that children are constitutionally different from adults for sentencing)
Lewis v. Continental Bank Corp., 494 U.S. 472 (vacatur and remand is appropriate where mootness results from intervening legal change)
Craft v. Memphis Light, Gas & Water Division, 534 F.2d 684 (discussing when relief for a plaintiff may benefit similarly situated nonparties)
Ball v. Wagers, 795 F.2d 579 (reversing denial of class certification where delay and mootness could bar review)
Tesmer v. Granholm, 333 F.3d 683 (declaring declaratory relief binds only named plaintiffs absent class certification)
Kowalski v. Tesmer, 543 U.S. 125 (reversing Tesmer on standing grounds)