People v. Stovall
987 N.W.2d 85 (2022)
Legal Analysis
Legal analysis from Dean's Law Dictionary will be displayed here.
Nature Of The Case
This section contains the nature of the case and procedural background.
Facts
While he was a juvenile, D fatally shot two men. He pled guilty in 1992 in two separate files to one count each of second-degree murder, and possession of a firearm during the commission of a felony in exchange for the dismissal of first-degree murder charges. The plea deal included a sentence agreement for life in prison with the possibility of parole (parolable life) for murder, consecutive to the mandatory two-year term for felony firearm. D moved to withdraw his plea. The trial court denied that motion. The Court of Appeals affirmed, and this Court denied leave to appeal in 1994. D filed multiple motions for relief from judgment, none of which succeeded. D filed this successive motion for relief from judgment in 2017, arguing that his plea was illusory and his sentences violated the Eighth Amendment of the United States Constitution under Miller v Alabama, 567 US 460 and Montgomery v Louisiana, 577 US 190 because he is effectively being denied a meaningful opportunity for release. The trial court denied the motion. The Court of Appeals denied leave to appeal. D appealed. On remand, a majority of the Court of Appeals affirmed the decision of the trial court. D again appealed here, repeating his same arguments. The court granted leave to appeal in part on whether D's sentences violate the prohibition against 'cruel and unusual punishments' in the Eighth Amendment, whether the Parole Board's 'life means life' policy renders D's sentences unconstitutional under Miller v Alabama, and Montgomery v Louisiana and whether, pursuant to Miller and Montgomery, the trial court was required to take D's youth into consideration when accepting his plea and ruling on his motion for relief from judgment; and whether the Parole Board is also required to take his youth into consideration when evaluating him for release on parole.
Issues
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Holding & Decision
The court's holding and decision will be displayed here.
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