People v. Woolfolk
857 N.W.2d 524
Mich.2014Background
- Defendant Deandre Woolfolk was involved in a fatal shooting between 10:00 and 11:00 p.m. on January 28, 2007, roughly one to two hours before his 18th birthday (born Jan. 29, 1989).
- A jury convicted Woolfolk of first-degree murder and felony-firearm; trial court imposed mandatory life without parole for murder plus a consecutive two-year term for felony-firearm.
- Woolfolk argued on appeal that, under Miller v. Alabama, mandatory life without parole is unconstitutional for those who were under 18 at the time of the offense, and he was still under 18 by his anniversary-of-birth calculation.
- The Michigan Court of Appeals affirmed the convictions but remanded for resentencing, holding age should be calculated by anniversary of birth rather than the English common-law rule that adds a day fraction.
- The Michigan Supreme Court agreed, holding that for Miller purposes a person is a juvenile if under 18 as determined by anniversary of birth; Woolfolk was under 18 at the time of the crime and is entitled to Miller treatment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| How to calculate whether a defendant was "under 18" for Miller | State: traditional common law age rule (age completed on day preceding birthday) governs | Woolfolk: age measured by anniversary of birth; he was under 18 at time of offense | Court: use anniversary-of-birth calculation; Woolfolk was under 18 and entitled to Miller protections |
| Whether English common-law rule (no fraction of a day) still governs Michigan | State: common law adopted at statehood supports the old rule | Woolfolk: prevailing modern practice and statutes favor anniversary calculation | Court: although common law adopted, modern practice and statutory references support changing rule to anniversary-based age |
| Whether convictions stand while resentencing under Miller required | State: convictions valid; sentencing issue only | Woolfolk: sentencing unconstitutional without Miller consideration | Court: convictions affirmed; remand for resentencing in accordance with Miller |
| Whether Supreme Court should review Court of Appeals' change to common-law understanding | State: sought leave to appeal the change | Woolfolk: cross-appeal denied | Court: affirmed Court of Appeals; denied leave to cross-appeal |
Key Cases Cited
- People v. Stevenson, 416 Mich. 383 (discussing adoption of common law unless abrogated) (state common-law adoption principle)
- In re Receivership of 11910 S Francis Rd, 492 Mich. 208 (common law adopted from England governs unless changed)
- People v. Duffield, 387 Mich. 300 (court may consult English authorities to identify common law)
- Bay Trust Co. v. Agricultural Life Ins. Co., 279 Mich. 248 (prior Michigan language consistent with anniversary-based age calculation)
- People v. Aaron, 409 Mich. 672 (dicta does not establish new common-law rule)
- Adkins v. Thomas Solvent Co., 440 Mich. 293 (court may alter common-law doctrines in light of societal change)
- Stitt v. Holland Abundant Life Fellowship, 462 Mich. 591 (court determines common-law rules that best serve Michigan citizens)
- Woodman v. Kera, LLC, 486 Mich. 228 (prevailing customs and practices inform common-law interpretations)
- Moning v. Alfono, 400 Mich. 425 (statutory policy may be considered when discerning common law)