In re Williams
333 Mich App 172
| Cal. Ct. App. | 2020Background
- Michael Williams was 21 when, during a robbery, he shot and killed two men; he was convicted of two counts of first-degree murder with special-circumstance findings and personally used a firearm. He received two consecutive life-without-parole (LWOP) terms. His direct appeal was affirmed.
- Williams filed a pro se habeas petition arguing exclusion from youth offender parole hearings under Penal Code section 3051(h) (which bars LWOP inmates who were 18 or older at the time of the offense from such hearings) violates equal protection and constitutes cruel and unusual punishment.
- Section 3051 (enacted 2013; expanded to under-24 in 2016 and under-26 in 2017) created youth offender parole hearings in response to Graham, Miller, Caballero, and Montgomery and legislative findings about continued brain development into the mid-20s; the statute expressly excludes LWOP offenders who were 18 or older at the time of the controlling offense.
- The court appointed counsel, issued an order to show cause, and ultimately denied the habeas petition.
- The court analyzed equal protection under rational-basis review and Eighth Amendment proportionality (cruel and unusual) claims, considering legislative purpose, differences among offenses (special-circumstance murders), and precedent on youth development and sentencing.
Issues
| Issue | Williams' Argument | Respondent's Argument | Held |
|---|---|---|---|
| Equal protection: does §3051's exclusion of LWOP inmates aged 18–25 deny equal protection? | Williams: LWOP inmates under 26 are similarly situated to non-LWOP youth offenders under 26 and should get parole hearings; exclusion is arbitrary. | State: Legislature rationally distinguished offenders based on crime severity (special-circumstance LWOP offenses) and legitimately excluded LWOP for those 18+; rational basis satisfied. | Court: No equal protection violation; groups not similarly situated with respect to culpability, and exclusion is rationally related to legitimate legislative purpose. |
| Eighth Amendment: is LWOP grossly disproportionate to Williams' culpability as a 21‑year‑old? | Williams: Youthful diminished culpability means LWOP is excessive and disproportionate. | State: Double special-circumstance murder is among the most heinous crimes; LWOP is proportional given severity and public safety. | Court: No cruel or unusual punishment violation; LWOP not grossly disproportionate to multiple intentional murders even for a 21‑year‑old. |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for juveniles; foundational youth-development rationale)
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment bars LWOP for nonhomicide juvenile offenders; requires meaningful opportunity for release)
- Miller v. Alabama, 567 U.S. 460 (2012) (Eighth Amendment bars mandatory LWOP for juveniles; emphasizes developmental differences)
- Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller made retroactive; states may remedy Miller error by parole consideration rather than resentencing)
- People v. Caballero, 55 Cal.4th 262 (2012) (California: de facto LWOP for juveniles unconstitutional; urged legislative parole mechanism)
- In re Kirchner, 2 Cal.5th 1040 (2017) (section 1170(d)(2) does not provide adequate Miller remedy)
- In re Dannenberg, 34 Cal.4th 1061 (2005) (California proportionality standard; gross disproportionality analysis)
- People v. Flores, 9 Cal.5th 371 (2020) (discusses age-line at 18 for death penalty eligibility and youth developmental evidence)
- People v. Turnage, 55 Cal.4th 62 (2012) (rational-basis review and limits on judicial second-guessing of legislative sentencing judgments)
- People v. Contreras, 4 Cal.5th 349 (2018) (observes murder's unique severity compared with nonhomicide crimes)