People of Michigan v. James Gregory Eads

CourtMichigan Court of Appeals
DecidedJanuary 16, 2025
Docket357332
StatusPublished

This text of People of Michigan v. James Gregory Eads (People of Michigan v. James Gregory Eads) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People of Michigan v. James Gregory Eads, (Mich. Ct. App. 2025).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, FOR PUBLICATION January 16, 2025 Plaintiff-Appellee, 12:13 PM

v No. 357332 Wayne Circuit Court JAMES GREGORY EADS, LC No. 92-007359-01-FC

Defendant-Appellant.

Before: MURRAY, P.J., and BORRELLO and MARIANI, JJ.

MURRAY, P.J. (dissenting).

The majority opinion concludes that, under People v Stovall, 510 Mich 301; 987 NW2d 85 (2022), and People v Bullock, 440 Mich 15; 485 NW2d 866 (1992), defendant’s individualized sentence to a term of years for his conviction of second-degree murder is unconstitutional as a cruel or unusual punishment.1 It then concludes that the sentence is also an unconstitutional cruel

1 It is not an efficient use of resources to provide another detailed view as to how our state Supreme Court has gone astray from the holding of Miller v Alabama, 567 US 460; 132 S Ct 2455; 183 L Ed 2d 407 (2012), to impose new constitutional sentencing requirements on sentencing decisions that do not involve mandatory sentences imposing the harshest possible sentence of life without the possibility of parole. I have done so before, People v Jackson, unpublished per curiam opinion of the Court of Appeals, issued May 9, 2024 (Docket No. 361540) (MURRAY, J., concurring), as have others. See People v Boykin, 510 Mich 171, 207-224; 987 NW2d 58 (2022) (ZAHRA, joined by VIVIANO, JJ., dissenting); People v Parks, 510 Mich 225, 278-300; 987 NW2d 161 (2022) (CLEMENT, C.J., joined by ZAHRA and VIVIANO, JJ., dissenting); Stovall, 510 Mich at 360-361 (ZAHRA, J., joined in large part by CLEMENT, C.J., and VIVIANO, J., dissenting) (“Each of these cases, standing alone, represents a significant departure from our jurisprudence in this area of the law. But taken as a whole, a bare majority of this Court (in all of the cases but Boykin) has dramatically rewritten the sentencing laws applicable to young people who commit society’s most heinous crimes. Defining crime and fixing punishment is emphatically a legislative task, in that it presents profound questions of policy and moral judgment best left for the Legislature to establish,

-1- or unusual punishment because it is a disproportionate sentence. For the reasons explained below, the majority incorrectly relies upon Stovall in reviewing defendant’s individualized, term-of-years sentence. Instead, the controlling decision is People v Boykin, 510 Mich 171-178; 987 NW2d 58 (2022), which requires a sentencing court to consider the circumstances of youth when sentencing a juvenile (defined by the Michigan Supreme Court as 18 or younger, at least for now) convicted of second-degree murder. And here the record shows that the trial court did consider defendant’s age, his poor upbringing and childhood, and other appropriate factors as required under People v Snow, 386 Mich 586; 194 NW2d 314 (1972). Thus, defendant’s sentence is constitutionally sound, and should be affirmed.

I. BULLOCK DOES NOT APPLY

The majority’s first conclusion is that under the four Bullock factors the 50 to 75-year sentence is unconstitutionally cruel or unusual. But Bullock, Stovall, People v Parks, 510 Mich 225, 232; 987 NW2d 161 (2022), and other cases all addressed statutorily prescribed sentences, most of which were mandatory. They were not reviewing an individualized, term-of-years sentence. Bullock, for example, addressed a challenge to the mandatory sentence of life without parole for possessing 650 grams or more of cocaine, see Bullock, 440 Mich at 21, while People v Lorentzen, 387 Mich 167, 170-171; 194 NW2d 827 (1972), upon which much of Bullock is premised, addressed a mandatory minimum of 20 years for possession of any amount of marijuana. Stovall, 510 Mich at 307-308, addressed the maximum statutory punishment for second-degree murder (as to those under 19) of life with the possibility of parole, while Parks addressed a challenge to mandatory life without parole for those under 18 convicted of first-degree murder, Parks, 510 Mich at 232.

In each of these decisions the Court applied the four-part Bullock/Lorentzen test to determine whether the specific statutory punishment was cruel or unusual under Article 1, § 16 of the Michigan Constitution. And, when looking at that four-part test, it seems evident that it is geared to testing the constitutionality of a specific, mandated statutory punishment, as it requires the reviewing court to compare the sentence mandated by the Legislature for the crime at issue with other statutory penalties in this state and across the nation. See Bullock, 440 Mich at 33- 34 (requiring courts to consider, inter alia, the penalty imposed for the offense compared to penalties imposed on other offenders in the same jurisdiction, and the penalty imposed for the offense in Michigan compared to the penalty imposed for the same offense in other states).

In applying that test, it is simply a matter of legal research to determine what the statutory punishment is for similar crimes here, and for the same offense in other states. A comparison is then made between what the Michigan Legislature deemed an appropriate sentence, and what other state legislative bodies have imposed for the same crime. But when a sentence is individualized, that comparison cannot be made by simply examining what other statutes in this or other states require, as an individualized, term-of-years sentence (particularly when not subject to a maximum

not for a slim majority of this Court to prescribe by judicial fiat.”); People v Abbatoy (“Abbatoy I”), unpublished per curiam opinion of the Court of Appeals, issued August 18, 2022 (Docket No. 357766) (BOONSTRA, J., concurring).

-2- cap) is based upon the defendant’s background, the facts and circumstances of the crime, and other relevant criteria considered in tailoring a proportionate sentence. In other words, individual, term- of-years sentences are not subject to comparison with mandatory statutory sentences when the underlying basis for those sentences is the particular and varying facts of the case.

Perhaps that is why, in the only recent challenge under Parks to a term of years sentence, the Court did not employ the Bullock/Lorentzen test, but instead held that to be constitutional, and consistent with the proportionality factors articulated in Snow and People v Milbourn, 435 Mich 630, 659-661; 461 NW2d 1 (1990), the attributes of youth of an offender under the age of 19 must be considered in rendering the individualized sentence. As the Boykin Court held, 510 Mich at 188-189:

Our sentencing caselaw focuses on the principle of proportionality, which requires sentences imposed “to be proportionate to the seriousness of the circumstances surrounding the offense and the offender.” Milbourn, 435 Mich at 636 (emphasis added). Accordingly, because the Supreme Court has held that youth—a circumstance of the offender—matters at sentencing, our own caselaw requires that such a relevant offender characteristic must be considered at sentencing. In Snow, this Court decided the legality of a sentence that was made harsher because the defendant decided to face trial rather than plead guilty. In holding that the defendant was entitled to resentencing because the record was silent about why the defendant’s sentence departed from the ordinary minimum sentence, this Court expressed the importance of four basic sentencing considerations. Snow, 386 Mich at 592, 594. Those four considerations are: (1) “reformation of the offender”; (2) “protection of society”; (3) “disciplining of the wrongdoer”; and (4) “deterrence of others from committing like offenses.” Id. at 592.

Youth affects these considerations.

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Related

Williams v. New York
337 U.S. 241 (Supreme Court, 1949)
Solem v. Helm
463 U.S. 277 (Supreme Court, 1983)
People v. Babcock
666 N.W.2d 231 (Michigan Supreme Court, 2003)
People v. Milbourn
461 N.W.2d 1 (Michigan Supreme Court, 1990)
People v. Cash
351 N.W.2d 822 (Michigan Supreme Court, 1984)
People v. Bullock
485 N.W.2d 866 (Michigan Supreme Court, 1992)
People v. Sabin
620 N.W.2d 19 (Michigan Court of Appeals, 2000)
Department of Transportation v. Randolph
610 N.W.2d 893 (Michigan Supreme Court, 2000)
People v. Powell
750 N.W.2d 607 (Michigan Court of Appeals, 2008)
People v. Adams
425 N.W.2d 437 (Michigan Supreme Court, 1988)
People v. Kowalski
601 N.W.2d 122 (Michigan Court of Appeals, 1999)
People v. Johnson
468 N.W.2d 307 (Michigan Court of Appeals, 1991)
People v. Lorentzen
194 N.W.2d 827 (Michigan Supreme Court, 1972)
People v. Snow
194 N.W.2d 314 (Michigan Supreme Court, 1972)
People v. Reynolds
611 N.W.2d 316 (Michigan Court of Appeals, 2000)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
People of Michigan v. Gregory Wines
916 N.W.2d 855 (Michigan Court of Appeals, 2018)

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Bluebook (online)
People of Michigan v. James Gregory Eads, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-james-gregory-eads-michctapp-2025.