People of Michigan v. Mark Alonzo Cowans, 330223

Defendant Mark Alonzo Cowans, age 17 at the time, and victim Ryan Hagerman were cellmates at Macomb County Jail; Hagerman died of severe head trauma after a violent assault in the cell.
A jury convicted Cowans of first-degree premeditated murder for repeatedly punching and kicking Hagerman’s head until he became unresponsive.
Because Cowans was a juvenile, the trial court held a MCL 769.25 sentencing hearing; the prosecutor sought life without parole but the court imposed a term-of-years sentence.
Shortly before the hearing, People v Skinner held that any fact making a juvenile eligible for life without parole must be found by a jury unless waived; Cowans waived a jury and the court proceeded without the prosecutor’s consent.
After sentencing to 30–60 years, subsequent appellate decisions (Perkins/Hyatt) clarified that a judge, not a jury, decides juvenile life eligibility; the Court of Appeals considered both the sufficiency-of-the-evidence challenge to the conviction and the prosecutor’s challenges to the sentencing process and term-of-years sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for first-degree premeditated murder	Prosecution: circumstantial evidence (brutal, repeated blows to head, pauses allowing reflection, concealment/lying) supports intent and premeditation	Cowans: evidence insufficient to show premeditation and deliberation	Affirmed: evidence supported intent to kill and premeditation/deliberation under totality of circumstances
Jury entitlement at MCL 769.25 sentencing hearing	Prosecutor: defendant cannot waive jury without prosecutor’s consent (MCL 763.3(1))	Cowans: he validly waived jury per Skinner and sentencing proceeded without prosecutor consent	Affirmed: trial court did not err; Hyatt later confirms judge decides juvenile life eligibility, so no jury entitlement to waive
Reasonableness of 30–60 year term-of-years sentence	Prosecutor: sentence unreasonable under Lockridge principle	Cowans: sentence within statutory MCL 769.25 range and supported by mitigating factors	Affirmed: trial court did not abuse discretion; sentence proportionate given brutality, age near 18, but also mitigating factors

Apprendi v. New Jersey, 530 U.S. 466 (statutory fact increasing penalty must be found by jury)
Blakely v. Washington, 542 U.S. 296 (same principle applied to state sentencing schemes)
Alleyne v. United States, 133 S. Ct. 2151 (facts increasing mandatory minimum must be submitted to jury)
Lockridge v. State, 498 Mich. 358 (Michigan: advisory guidelines and Lockridge reasonableness review)
Milbourn v. Lewis, 435 Mich. 630 (principle of proportionality governs sentence reasonableness)
Skinner v. People, 312 Mich. App. 15 (juvenile default term-of-years; facts raising life eligibility must be jury-found unless waived)
Plummer v. People, 229 Mich. App. 293 (premeditation defined; undisturbed thought process)
Van Camp v. People, 356 Mich. 593 (kicking to death can support first-degree murder)