People v. Langston

Summary

The Michigan Supreme Court held that mandatory life without parole (LWOP) for felony-murder convictions entered before People v Aaron (1980) violates Const 1963, art 1, § 16's ban on cruel or unusual punishment when the jury was never instructed to find malice as Aaron defines it, unless the prosecution proves beyond a reasonable doubt, from the trial evidence, that a jury would have found such malice anyway. The court announced a two-part burden-shifting framework, held that the remedy is to strike the no-parole aspect of the sentence so the defendant becomes parole-eligible, declined to overrule Hall, found good cause under MCR 6.508(D)(3) based on later-developed sentencing jurisprudence, and concluded that Langston's own 1976 jury was not instructed on Aaron-defined malice. It vacated in part the order denying relief from judgment and remanded for expedited proceedings while denying review of whether Aaron's prospective-only limit was correct. Chief Justice Cavanagh, concurring in part and dissenting in part, would have struck the no-parole aspect and resentenced immediately without allowing the prosecutor to relitigate malice, and Justice Zahra, dissenting, would have denied relief outright on finality and good-cause grounds.