People v. Skinner
312 Mich. App. 15
| Mich. Ct. App. | 2015Background
- In 2010, when she was 17, defendant Skinner arranged the murder of her parents; a jury convicted her of first-degree premeditated murder and related offenses. She was initially sentenced to mandatory life without parole for first-degree murder.
- After Miller v. Alabama (2012) invalidated mandatory juvenile LWOP, Michigan enacted MCL 769.25 (2014) creating a default term‑of‑years for juvenile first‑degree murderers and permitting prosecution to move for LWOP; if prosecution moves, the trial court must “consider” Miller factors at a sentencing hearing.
- Skinner was resentenced multiple times; at the third resentencing she requested a jury to decide the Miller factors under MCL 769.25(6) and was denied. She appealed, arguing MCL 769.25 violates her Sixth Amendment jury right because judicial fact‑finding exposed her to LWOP beyond the verdict.
- The panel reviewed federal Sixth and Eighth Amendment precedents (Apprendi, Ring, Blakely, Cunningham, Alleyne) and Miller/Graham/Roper on juvenile sentencing, and Michigan decisions (Carp, Lockridge) addressing post‑Miller sentencing changes.
- Holding: the court concluded MCL 769.25 is unconstitutional to the extent that it allows a judge (rather than a jury) to make the factual findings that would increase a juvenile defendant’s sentence from the statutory term‑of‑years default to life without parole; Skinner’s LWOP sentence was vacated and remanded for resentencing with a jury determination on those facts (unless waived).
Issues
| Issue | Plaintiff's Argument (Skinner) | Defendant/State's Argument | Held |
|---|---|---|---|
| Whether MCL 769.25 permits judicial fact‑finding that increases a juvenile first‑degree murderer's authorized sentence to LWOP in violation of the Sixth Amendment | MCL 769.25 makes LWOP contingent on judicial findings; those findings increase the statutory maximum beyond the verdict and therefore must be found by a jury beyond a reasonable doubt (Apprendi line). | The statutory maximum for first‑degree murder is LWOP; no additional facts are required to impose LWOP, and the statute only requires the court to "consider" Miller factors (discretionary sentencing factors). | The court held the Miller factors (as codified in MCL 769.25(6)) functionally increase punishment and thus must be found by a jury beyond a reasonable doubt; Skinner’s LWOP sentence vacated and remanded for jury determination (unless waived). |
| Remedy / Severability: Who decides and how to proceed on remand | N/A (issue concerns implementation) | N/A | The court severed the unconstitutional application and directed that, when prosecutor seeks LWOP, a jury must be empaneled to hear evidence and determine beyond a reasonable doubt whether the juvenile’s offense reflects "irreparable corruption" per Miller; if jury rejects LWOP, judge imposes the statutory term‑of‑years. |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (Eighth Amendment forbids mandatory LWOP for juveniles; individualized inquiry required; LWOP permissible only in rare "irreparable corruption" cases)
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (other than prior convictions, any fact that increases penalty beyond prescribed statutory maximum must be submitted to a jury and proved beyond a reasonable doubt)
- Ring v. Arizona, 536 U.S. 584 (2002) (capital aggravating‑factor findings that expose defendant to greater punishment must be found by a jury)
- Blakely v. Washington, 542 U.S. 296 (2004) (statutory maximum for Apprendi purposes is the maximum a judge may impose based only on facts in the jury verdict or admitted by defendant)
- Cunningham v. California, 549 U.S. 270 (2007) (sentencing schemes that assign to judges sole authority to find facts permitting enhanced terms violate the Sixth Amendment)
- Alleyne v. United States, 570 U.S. 99 (2013) (Apprendi rule applies to facts that increase mandatory minimums; elements that alter legally prescribed punishment must be submitted to a jury)
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles categorically ineligible for death penalty; juveniles have diminished culpability)
- Graham v. Florida, 560 U.S. 48 (2010) (categorical bar on LWOP for juvenile nonhomicide offenders; juveniles entitled to meaningful opportunity for release)
- People v. Lockridge, 498 Mich. 358 (2015) (Michigan sentencing guidelines found constitutionally deficient under Alleyne; guidelines rendered advisory)
- People v. Carp, 496 Mich. 440 (2014) (describing MCL 769.25 as establishing a default term‑of‑years for juvenile first‑degree murderers absent a prosecutor’s motion for LWOP)