Michigan teens and young adults ordered to spend essentially their entire lives in prison are poised to receive new sentences under a recent Michigan Supreme Court ruling.
The 6-1 decision issued July 30 from the state's high court affects any offender 21 and younger sentenced to decades in prison. The impact is historic and expansive, said Marty Berger, an ACLU of Michigan fellow who coordinated a brief filed on the case.
"The Michigan Supreme Court said that it is cruel or unusual to sentence somebody who committed a crime as a youth to a de facto life sentence. And the million dollar question going forward will be what a de facto life sentence means in practice," Berger said.
In this specific case, James Eads received 50-75 years in prison after
he was convicted of second-degree murder. He was 16 at the time of the killing − even though he was not sentenced to life in prison, his sentence all but ensures he would die in prison. This ruling, though, determined trial courts failed – for decades – to appropriately take into account a defendant's age when weighing their fate, at times resulting in lengthy sentences that violate constitutional protections against cruel and unusual punishment.
Maya Menlo, assistant youth appellate defender with the State Appellate Defender's Office, said the new ruling means anyone convicted of a crime under age 21 who received a similarly "extreme" sentence is eligible for resentencing.
"The United States Supreme Court, the Michigan Supreme Court, and the Michigan Legislature have all repeatedly recognized that young people deserve special consideration at sentencing," said Menlo, who filed what's known as an amicus brief in this case calling on the court to rule as it did.
"The State Appellate Defender Office applauds this decision and agrees wholeheartedly that young people should have opportunities to rehabilitate and rejoin society."
This ruling follows a similar decision in 2022, where the Michigan Supreme Court determined a youthful offender sentenced to life in prison with the possibility of parole is also cruel and unusual punishment under the Michigan Constitution. The high court relied heavily on that decision in this case.
"This sentence is out of step with national trends regarding youth sentencing and with the types of sentences other jurisdictions typically impose on anyone convicted of second-degree murder, and it does not meaningfully advance the penological goal of rehabilitation," the majority opinion states.
Justice Kimberly Thomas wrote the opinion, with Chief Justice Megan Cavanagh and fellow justices Richard Bernstein, Elizabeth Welch, Kyra Bolden and Noah Hood formally signing on to her ruling. Justice Brian Zahra wrote a dissent, arguing procedure should ban the majority's decision and even if it didn't, the underlying sentence does not amount to cruel and unusual punishment.
It's unclear how many people are eligible for new sentences, but they'll likely to need to formally file in court to request a resentencing.
The ruling is the latest in a series of decisions from Michigan’s high court that aims to prevent unlimited prison time for someone convicted of any crime committed while they were 21 or younger.
It also comes as other states across the country push for comparable reforms, arguing courts repeatedly failed to adequately take into account the age of someone convicted of a heinous crime before determining the will likely die in prison.
"Other people were sentenced when they were young are going to have the benefit of this decision even if they weren't sentenced to the same amount of times as Mr. Eads was, and even if they weren't convicted of the same offense that Mr. Eads was," Berger said, adding the ruling builds on years of legal work and related court decisions.
"[This ruling] is the next step in the progression toward...chipping away at a system that treats young people who commit crimes as disposable, a system that locks kids away for the rest of their lives and throws away the key."
'I really think he should not be out until he reaches about 50 years of age'
In 1992, the 16-year-old Eads shot and killed 17-year-old Eric Kincaid in Detroit after Kincaid and a group of other young men approached the car where Eads sat. Eads later told investigators he was a member of a gang and thought Kincaid and the other people were members of a rival gang attempting to hurt him.
Eads was charged with first-degree murder and committing a felony while having a firearm. Ultimately, a jury convicted him of second-degree murder and the felony firearm charge.
Although sentencing guidelines suggested Eads receive a minimum of 12 to 25 years in prison, prosecutors and Kincaid’s family pushed a Wayne County judge to levy a far harsher punishment. At one point, prosecutors called for a sentence ranging from 60 to 120 years, a term they thought would deter others and “protect the rest of us from his type,” court records state.
ACLU of Michigan Legal Director Bonsitu Kitaba-Gaviglio reflected on the broader circumstances that led to the lengthy sentence for Eads − and many others in Michigan prisons.
“These rare and highly punitive sentences are almost exclusively imposed on youth of color, compounding both their disproportionality and their cruelty. This decision should serve as a model to courts across the country: there is a different path," Kitaba-Gaviglio said in a statement last week.
"Young people don’t choose the poverty, the trauma, or the broken systems that so often draw them into the criminal legal system—and we cannot in good conscience blame a child for the failures of the world around them, then hand down our harshest punishment as if they had."
Eads defense team argued at the time of his original trial their client endured a traumatic upbringing. Before he was sentenced, Eads told the court he lived on his own from the age of 11, after his father’s death.
“He had become involved in a gang then because the gang ‘gave [him] a home when no one else would’ and ‘[t]he only way for [him] to survive poverty and homelessness was through gang membership’,” court records state.
The judge, longtime Circuit Court Judge John Hausner, sided with prosecutors. He levied a 50-75 year sentence on the second-degree murder charge, double the recommendation. He also sentenced Eads to two years on the firearm charge, to be served consecutively to the murder sentence.
It was the first time in his career he levied a sentence outside the guidelines, Hausner said, according to court records. But the case warranted it, he said.
“I consider this to be the most unprovoked crime I’ve ever had in my 17 years as a judge. There’s no provocation, there’s no reason to have killed this person,” Hausner said, according to court records.
“I really think he should not be out until he reaches about 50 years of age, and that would be the proper age for him to—if he’s demonstrated he can survive and behave in a structured discipline.”
At the time, Eads appealed his sentence. The appeals failed.
But in 2021, he filed again, pointing to a 2012 U.S. Supreme Court decision related to life sentences for juveniles. His case percolated through the court system again; ultimately, the Michigan Supreme Court ordered the state appeals court to review it in light of two state court decisions.
Those decisions proved pivotal to Eads’ case.
Ruling builds on years of other cases
In 2012, the U.S. Supreme Court determined life sentences without the possibility of parole for people convicted of crimes committed as juveniles amounted to cruel and unusual punishment.
Subsequently, the Michigan Supreme Court issued several opinions going beyond this ruling: in 2022, the court determined life sentences with the possibility for parole for juveniles were also unconstitutional. The same year, the court ruled when judges levy any sentence for a juvenile, they must adequately weigh the person’s age before issuing the sentence.
In light of both decisions, in 2025 the Michigan Court of Appeals determined Eads’ sentence was improper and ordered he receive a new one.
It was a 2-1 split decision. The Wayne County prosecutor’s office appealed the appellate court decision, moving the case to the state supreme court. They argued the state’s high court got it wrong when it decided a life sentence with parole for a juvenile convicted of second-degree murder was cruel and unusual punishment.
“It is rather shocking that today, rather than ‘public sentiment condemning’ a particular punishment as cruel through the enacted political representatives in whom rests the responsibility for the creation of offenses and the establishment of punishments for their violation, the judiciary views itself — an elite group — as ‘the public’,” prosecutors wrote in a brief to the Michigan Supreme Court.
“If public sentiment viewed the penalty for those under 18 for 2nd-degree murder as inhumane, one would expect to see it expressed through the political representatives of the State. How are seven — or six, or five, or four — lawyers better equipped?”
The high court disagreed,pushing back on the prosecutor's arguments about legislative intent.
"A sentence might be considered reasonable when viewed in the context of the Michigan legislative scheme yet beconsidered disproportionate under [the Michigan Constitution]," the majority ruling issued last week states.
"It would be inappropriate to interpret a doctrine premised on legislative intent as cutting off an independent constitutional analysis that, by its nature, serves as a limitation on the Legislature’s authority."
Dave Boucher is an investigative reporter at the Detroit Free Press. Reach him at dboucher@freepress.com.
This article originally appeared on Detroit Free Press: Michigan Supreme Court allows new sentences for youthful offenders
