People v. Eliason, 300 Mich. App. 293

Defendant Dakotah Eliason, age 14 at the time, was convicted of first‑degree premeditated murder and felony‑firearm; he received mandatory life without parole for murder and two years for felony firearm; on appeal, convictions were affirmed and sentencing remanded for individualized consideration.
On March 5–6, 2010, Eliason spent the weekend at his grandparents’ home; the victim, Jesse Miles, was killed while sleeping on a couch after Eliason retrieved a handgun from a coat rack.
Eliason’s post‑shooting statements to law enforcement described premeditation and contemplation of either suicide or killing Jesse; he claimed anger toward his own parents rather than Jesse or Jean.
Defense argued ineffective assistance for not presenting an expert to rebut claims of lack of remorse; trial counsel had consulted three mental health experts who did not support a dissociation defense.
The admission of statements to Casto and Kiefer and the voluntariness/knowing nature of the Miranda waivers were challenged, with the trial court finding the waivers voluntary and knowing for a fourteen‑year‑old.
The court held Miller v. Alabama requires individualized sentencing for juveniles in first‑degree murder cases and vacated the mandatory life‑without‑parole sentence, remanding for an individualized determination; the majority remanded under Miller, while a concurrence/ dissent debated the scope of sentencing discretion under Michigan law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mandatory life without parole for juveniles violated Miller	Miller requires individualized sentencing and allows parole consideration	Michigan’s statute permits only LWP or LWP with no meaningful parole option	Remand for an individualized sentence; not a fixed reimposition of LWP
Validity of the Miranda waivers by a 14‑year‑old	Waivers were knowing and voluntary given the totality of circumstances	Waivers were involuntary/unclear due to youth	Waivers knowingly and intelligently made; voluntary under Givans factors
Ineffective assistance of counsel related to lack of an expert on remorse	Expert testimony could rebut lack of remorse claim	Counsel strategically chose to impeach and rely on other evidence	No ineffective assistance; strategy reasonable; no prejudice shown

Miller v. Alabama, 132 S. Ct. 2455 (2012) (2012) (mandatory life without parole for juveniles unconstitutional; requires individualized sentencing)
Graham v. Florida, 560 U.S. 49 (2010) (2010) (youth considerations in proportionality for nonhomicide offenses; rehabilitation focus)
Roper v. Simmons, 543 U.S. 551 (2005) (2005) (youth distinctions in capital sentencing; prohibits execution of juveniles)
Lorentzen v. People, 387 Mich. 167, 194 N.W.2d 827 (1972) (1972) (Michigan Constitution proportionality; rehabilitation focus; decency test)
People v Carp, 298 Mich. App. 472, 828 N.W.2d 685 (2012) (2012) (Miller dicta on sentencing juveniles; limits of remand discretion in Michigan)
People v. Pickens, 446 Mich. 298, 521 N.W.2d 797 (1994) (1994) (standard for ineffective assistance analysis)