People of Michigan v. Montez Stovall

Summary

The Michigan Supreme Court held that defendant's successive motion for relief from judgment was not procedurally barred and that his guilty plea was not illusory because he received the benefit of parole eligibility in exchange for avoiding first-degree-murder charges. Although the sentence did not violate the federal prohibition against cruel and unusual punishment, the Court held that life with the possibility of parole imposed for a juvenile's second-degree murder violated the Michigan Constitution's broader prohibition against cruel or unusual punishment under the state proportionality test. The Court vacated the sentence and remanded for further proceedings.