Michigan Supreme Court Weighs Whether 50-Year Prison Term Constitutes De Facto Life Sentence for Juvenile Offender

Michigan Supreme Court to Decide Whether Long Terms Violate State Constitution for Young Offenders

LANSING — The Michigan Supreme Court heard oral arguments Wednesday in a case that could reshape sentencing guidelines for dozens of inmates who committed crimes as children. The justices are considering whether a 50 to 75 year prison term for a person who was 16 when he committed second-degree murder constitutes a de facto life sentence under the state constitution.

The case involves James Gregory Eads, who was convicted in 1992 of shooting and killing 17-year-old Eric Kincaid on a Detroit street. Eads pulled a gun after seeing the victim wearing a T-shirt with the name of a rival gang called the Latin Counts. Recorder's Court Judge John Hausner sentenced him to 50 to 75 years, well above the sentencing guidelines.

The Michigan Supreme Court has already dramatically expanded protections for juveniles and young adults against long sentences. In 2022, it ruled in People v. Stovall that life sentences for second-degree murder for juveniles, even with the possibility for parole, violate the state constitution. The same year, in People v. Boykin, it held that courts must consider youth as a mitigating factor in sentencing.

The Court has already ruled that sentencing a juvenile to life for second-degree murder violates the state's constitutional provision against cruel or unusual punishment, said defense attorney Phillip Comorski. If I agree with you on this, where would we draw the dividing point on what counts as a de facto life sentence?

The Wayne County Prosecutor's Office appealed a Court of Appeals ruling that found Eads should be resentenced under more lenient guidelines. Special Assistant Prosecutor Timothy Baughman argued before the justices that the Court's efforts to secure leniency for juvenile defendants have strayed into territory better reserved for state lawmakers.

The legislature has since statehood not said, We're going to treat juveniles, as a categorical matter, differently than we treat adults, said Baughman. That is their decision to make.

How Far Does This Rule Reach?

If the justices rule in Eads favor, the decision could have implications for dozens of inmates. A national advocacy organization filed an amicus brief identifying 67 inmates whose sentences would potentially be impacted.

Comorski suggested the ruling could establish 39 years as a barometer for what constitutes a disproportionately harsh sentence, citing the U.S. Sentencing Commissions definition of a de facto life sentence for federal courts.

Should it be a term that they abide by like a sentencing guideline or should it be a particular number that, if you exceed that, it's presumptively disproportionate, Comorski asked. He suggested whatever the court decides could have consequences beyond this case.

Defense attorney Charity Lee represented Donyelle Michael Black in a second case the Supreme Court heard Wednesday. Black was sentenced to life without parole for a 1987 rape and murder he committed while 15.

Prosecution Argues Victims Must Relive Pain

Prosecutors argue they must keep bringing cases when courts rule against them to try to figure out where the contours of these decisions are going to lead, said Jon Wojtala, appellate chief with the Wayne County Prosecutor's Office.

He added that every time courts declare years-old punishments unconstitutional, victims, their families, and others impacted must relive their past pain.

Where this path ends, we can't predict, Wojtala said. So that's one of the reasons why we keep bringing these cases when they are decided against us, whether it's in the Court of Appeals, or in the Supreme Court.

The Court is expected to rule in the Eads case before the current session ends in July.

Key Facts

• James Eads was 16 when he shot and killed 17-year-old Eric Kincaid in 1992
• Eads received a 50 to 75 year sentence, well above sentencing guidelines
• The Court of Appeals ruled Eads should be resentenced based on 2022 Supreme Court rulings
• Wayne County prosecutors appealed that ruling to the state Supreme Court
• A national advocacy group identified 67 inmates whose sentences could be affected
• The Court is expected to rule before July 2026