People v. Taylor and People v. Czarnecki

People v. Taylor and People v. Czarnecki consider whether mandatory life without parole (LWOP) for emerging adults who were convicted of offenses committed at the age of nineteen or twenty constitutes “cruel or unusual” punishment under the Michigan Constitution. In joining Mr. Taylor’s and Mr. Czarnecki’s fight as amici, the MacArthur Justice Center, along with the State Law Research Initiative, argue that all mandatory life-without-parole sentences are per se cruel under the Michigan Constitution and that therefore, at a minimum, sentencing emerging adults to mandatory life without parole is also unconstitutionally cruel. 

Mr. Taylor is serving a mandatory life-without-parole sentence for a crime he committed when he was twenty years old, and Mr. Czarnecki is serving a mandatory life-without-parole sentence for a crime he committed when he was nineteen. Both argued on appeal that their sentences violated the Michigan Constitution’s prohibition against “cruel or unusual” punishment. 

In 2022, the Michigan Supreme Court held, in People v. Parks, that a mandatory life-without-parole sentence for an eighteen-year-old violates Michigan’s “cruel or unusual” punishment clause because adolescent development continues beyond the current legal age of majority. As a result, the Michigan Supreme Court scheduled Taylor and Czarnecki to be argued in the same sitting on the question of whether the holding in Parks should be extended to nineteen- and/or twenty-year-olds. That same day, the Court will also be hearing a case—People v. Langston—considering whether mandatory life without parole for felony murder, absent a showing that the defendant acted with malice or intent to kill, constitutes “cruel or unusual” punishment. 

The MacArthur Justice Center (MJC), along with our partners at the State Law Research Initiative (SLRI) and local counsel Allison Kriger of LaRene & Kriger PLC, filed an amicus brief in support of Mr. Taylor’s and Mr. Czarnecki’s position—as we similarly have in Langston—arguing that the Michigan Constitution’s cruel or unusual punishment clause prohibits punishments that foreclose altogether the possibility of an individual’s rehabilitation. This meaning of the clause comports with the drafting and constitutional history of the Michigan Constitution, including Michigan’s early abolition of capital punishment, and the state longstanding history of rehabilitative sentencing and clemency practices. In fact, for most of Michigan’s history, modern life without the possibility of parole—that is, “death-by-incarceration”—did not exist. Rather, Michigan governors so routinely exercised their clemency power that nearly sixty of the people sentenced to life without parole for first-degree murder between 1900 and 1969 were eventually released by commutation, with each serving an average of fewer than 24 years. 

That all changed in the 1980s and ’90s, and today Michigan’s life-without-parole scheme virtually forecloses any possibility of release for thousands of Michiganders, regardless of their potential or actual rehabilitation—an abandonment of the State’s constitutional commitment to the ideal of rehabilitation.  MJC and SLRI urge the Michigan Supreme Court to uphold its constitutional duty and hold that mandatorily sentencing an emerging adult to life without parole without the safeguards of individualized sentencing is unconstitutionally cruel. 

UPDATE

On April 10, 2025, the Michigan Supreme Court issued a favorable decision, ruling that mandatory LWOP for 19- and 20-year-olds violates the Michigan Constitution’s ban on “cruel or unusual” punishments.  In doing so, it becomes the third state in the nation to extend individualized sentencing protections to persons under 21 as a state constitutional matter.  The Court’s discussion of Michigan’s “Traditional Goal of and Preference for Rehabilitation” – a key factor in its constitutional analysis – draws heavily from the historical research set forth in MJC’s and SLRI’s joint amicus brief.