People v. Langston 2026 LEXIS 1472 (Mich. 2026)

The Supreme Court of Michigan overturned and vacated Mr. Langston’s conviction in part and remanded the case to the trial court for further proceedings, finding that the imposition of mandatory LWOP for pre-Aaron felony-murder convictions constitutes cruel or unusual punishment under Article 1, § 16 of the Michigan Constitution.

The court reasoned in part, “[S]ignificant jurisprudential developments in constitutional sentencing law have since occurred. Beginning in 2010, a series of United States Supreme Court decisions imposed new constitutional limitations on mandatory LWOP sentences for juvenile offenders. First, the Court held that sentencing a juvenile to LWOP for a nonhomicide
offense violates the Eighth Amendment’s prohibition of “cruel and unusual” punishments. Graham v Florida, 560 US 48, 82; 130 S Ct 2011; 176 L Ed 2d 825 (2010). Soon after, the Court held that the same constitutional infirmity exists with the imposition of
mandatory LWOP for juveniles convicted of homicide. Miller v Alabama, 567 US 460, 465; 132 S Ct 2455; 183 L Ed 2d 407 (2012).

The Court later held that its decision in Miller applies retroactively to cases on collateral review. Montgomery v Louisiana, 577 US 190, 206; 136 S Ct 718; 193 L Ed 2d 599 (2016). Although published after the instant motion was filed, this Court has expanded on the protections set forth in Graham and Miller in cases holding that mandatory LWOP for offenders under 21 years old violates
Michigan’s prohibition on “cruel or unusual” punishment. People v Parks, 510 Mich 225, 266; 987 NW2d 161 (2022); People v Taylor, ___ Mich ___, ___; ___ NW3d ___ (April 10, 2025) (Docket No. 166428); slip op at 2.10

While these cited cases are not dispositive of the issue before us, they mark a consistent trend away from the mandatory imposition of LWOP for first-degree murder when that punishment is not “tailored to a defendant’s personal responsibility and moral guilt.” Taylor, ___ Mich at ___; slip op at 22 (quotation marks and citation omitted). These developments in precedent establish good cause under MCR 6.508(D) because they provide a reasonable legal basis for the cruel-or-unusual-punishment argument that did not exist at the time of his prior appeals. See Reed, 449 Mich at 385 n 8.12 Having established that Langston showed good cause, we turn to actual prejudice. MCR 6.508(D)(3)(b).

. . .

We hold that mandatory LWOP for pre-Aaron felony murder constitutes cruel or unusual punishment under Article 1, § 16 of the Michigan Constitution if two conditions are met. The defendant must first establish that the jury was not instructed on malice as defined by Aaron. If so established, the burden shifts to the prosecution to show beyond a reasonable doubt, on the basis of the evidence presented at trial, that a jury would have found that the defendant acted with malice as defined by Aaron had it been so instructed. If the prosecution cannot meet its burden, the remedy is to strike the no-parole aspect of the LWOP sentence, which would render any defendant who qualifies eligible for parole consideration.”