People v. Langston

Summary

The Michigan Supreme Court held that mandatory life without parole (LWOP) for felony-murder convictions entered before its 1980 decision in People v Aaron violates Const 1963, art 1, § 16's ban on cruel or unusual punishment where the jury was never instructed on 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. The court announced a two-part burden-shifting test, adopted striking the no-parole aspect of the sentence as the remedy, concluded that Langston's 1976 jury instructions fell short of the Aaron malice standard, and remanded for the prosecution to meet its burden; it declined to revisit Aaron's prospective-only limit and left People v Hall intact outside the new framework. Chief Justice Cavanagh, concurring in part and dissenting in part, would have struck the no-parole aspect outright without any prosecution rebuttal stage, criticizing the majority's turn to harmless-error and capital-sentencing doctrine; Justice Zahra, dissenting, would have denied relief on finality and good-cause grounds.