People of Michigan v. Kenya Ali Hyatt
325741
| Mich. Ct. App. | Jul 21, 2016Background
- Defendant Kenya Ali Hyatt, 17 at the time, was sentenced to life without parole for homicide-related offenses; the case reached the Michigan Court of Appeals on appeal.
- A psychologist testified about Hyatt’s capacity for change, stating she could not predict improvement and that a five‑year prediction of change "would not be possible."
- The sentencing court considered factors related to Hyatt’s youth and character (juvenile status, lack of remorse, assaultive history, perceived absence of conscience, serious maladjustment) and imposed LWOP.
- The concurrence (Judge Meter) agreed with parts of the majority opinion but dissented from the decision to vacate the sentence and remand for resentencing.
- Judge Meter argued the Milbourn proportionality framework was properly applied and that the sentencing court adequately considered Miller factors in reaching a constitutional decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentence must be vacated and remanded for resentencing because juvenile status requires special consideration under Miller | State maintained the sentence was lawful given sentencing court’s findings | Hyatt argued juvenile status and Miller require resentencing to consider youth-related factors and rarity of LWOP for juveniles | Concurrence: No remand — sentencing court applied proportionality and considered Miller factors; would affirm sentence |
| Whether Milbourn proportionality review suffices for juvenile LWOP cases | Milbourn provides adequate framework for proportionality review in this case | Hyatt contended Miller/Montgomery require a different or heightened inquiry for juveniles | Concurrence: Milbourn is adequate; sentencing court explicitly referenced proportionality and considered juvenile-related factors |
| Whether psychologist’s pessimistic prognosis required a different outcome | State relied on psychologist’s testimony among other evidence showing low rehabilitation potential | Hyatt argued testimony about inability to predict change suggested potential for rehabilitation and counseled resentencing | Concurrence: Psychologist’s remark was one piece of evidence; overall record supported low potential for rehabilitation and LWOP |
| Whether factual circumstances justified LWOP despite juvenile status | State argued defendant was the shooter, had assaultive history, no remorse, and serious maladjustment, supporting LWOP | Hyatt challenged the weight given to these factors given juvenile mitigating considerations | Concurrence: These circumstances did not "most suggest" rehabilitation; sentence proportionate and constitutional |
Key Cases Cited
- People v. Milbourn, 435 Mich. 630; 461 N.W.2d 1 (1990) (Michigan proportionality framework for reviewing sentences)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles unconstitutional; youth-related factors must be considered)
- Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller applies retroactively and emphasizes rarity of juvenile LWOP)