People of Michigan v. Montez Stovall

Summary

The court held that the defendant’s successive motion for relief from judgment was not procedurally barred and that his guilty plea was not illusory because it provided the benefit of parole eligibility and avoided the risk of a first-degree-murder conviction. Although the sentence did not violate the Eighth Amendment, the court held that life with the possibility of parole for a juvenile convicted of second-degree murder was cruel or unusual under the Michigan Constitution because it was disproportionate under Michigan’s four-factor sentencing test. The court reversed the Court of Appeals, vacated the murder sentence, and remanded for further proceedings.