People v. Woolfolk
304 Mich. App. 450
| Mich. Ct. App. | 2014Background
- Detroit shooting on Jan. 28, 2007; victim Mone Little killed; defendant identified by Watson using his nickname; Watson testified under use immunity; defendant convicted of first-degree murder and felony firearm; life without parole plus two-year sentence; Miller v Alabama subset discussion pending resentencing; defendant born Jan 29, 1989; offense occurred the night before his 18th birthday.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prearrest delay violated due process or trial counsel’s duty to object | People argues no due process violation; delay reasonable under circumstances | Woolfolk asserts delay prejudiced defense and trial counsel should have objected | Delay not shown to cause actual prejudice; delay reasonable; no plain error |
| Whether the identification procedure violated due process | People contends photo display was not unduly suggestive given witness identification | Woolfolk contends single-photo ID could cause misidentification | Single-photo ID did not create substantial likelihood of misidentification under the totality of circumstances |
| Whether Miller requires resentencing due to age at the time of the crime | People argues Miller applies to juveniles and mandates reconsideration | Woolfolk contends Michigan should apply common-law age rule or argue no Miller remedy | Birthday rule applies; Miller mandates resentencing; common-law rule abrogated |
| Whether Michigan should apply the birthday rule or common-law rule for age calculation | People argues legislative and judicial action imply birthday rule | Woolfolk argues common-law rule may apply | Birthday rule applies in Michigan; common-law rule abrogated |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (Eighth Amendment; life without parole for under 18 violates ban on mandatory LWOP for juveniles)
- Carp v. People, 828 N.W.2d 685 (Mich. Ct. App. 2012) (Miller applied to juveniles; in Michigan, sentencing considerations for youths)
- Bay Trust Co. v. Agricultural Life Ins. Co., 271 N.W.2d 749 (Mich. 1937) (Early Michigan acknowledgment of age concepts in common-law context)
- O’Neill v. Morse, 188 N.W.2d 785 (Mich. 1971) (Commentary on birth as arbitrary but taken as age-change marker)
- Smith v. Smith, 447 N.W.2d 715 (Mich. 1989) (Age of majority interaction with child-support provisions; birthday-related reasoning)