When Alex Adamowicz challenged the life-without-parole sentence he received for a crime he committed as a struggling 21-year-old, arguing that it violated the Michigan Constitution’s ban on cruel or unusual punishment, the Court of Appeals chastised him for even attempting. Joining Mr. Adamowicz’s fight as amici to ask that the Michigan Supreme Court review his case, the MacArthur Justice Center is urging states with expansive Eighth Amendment analogues, like Michigan, to lead the charge in ensuring humane sentencing for youth and for all that offers meaningful opportunities for rehabilitation and release.
Mr. Adamowicz is serving a mandatory life-without-parole sentence for a crime he committed when he was 21 years old and suffering from PTSD. He argued on appeal that his sentence violated the Michigan State Constitution’s Eight Amendment equivalent against cruel or unusual punishment.
Following its holding in People v. Parks that a mandatory life-without-parole sentence for an 18-year-old violates Michigan’s constitutional ban on cruel or unusual punishment because adolescent development continues beyond the current legal age of majority, the Michigan Supreme Court remanded Mr. Adamowicz’s case to the Court of Appeals. The court’s decision in Parks rested on adolescent development research showing that the attributes that make youth under 18 less culpable for their actions and more malleable as they mature persist well into one’s 20s.
In its opinion, the Court of Appeals scolded Mr. Adamowicz for continuing to fight his sentence and rejected his challenge. It noted that the Michigan Supreme Court had limited its constitutional holding to defendants who were age 18, and without addressing the Parks court’s discussion of adolescent brain development, it concluded that nothing else compelled a different result.
The MacArthur Justice Center (MJC) filed an amicus brief in support of Mr. Adamowicz’s position, arguing that, as the Michigan Supreme Court has embraced, the Michigan Constitution’s ban on cruel or unusual punishment is meant to be more protective than the Eighth Amendment’s ban on cruel and unusual punishment. Michigan society has long protected its youth and valued proportionate punishments, and that the Court’s conclusion in Parks applies here: there is no relevant developmental difference between an 18-year-old and a 21-year-old. Therefore, mandatory life-without-parole sentences for 21-year-old runs afoul of the Michigan Constitution.