People v. Hyatt

Juvenile Law Center filed an amicus brief in the Michigan Supreme Court on behalf of Kenya Hyatt, who was sentenced to life without parole under a theory of felony murder for his participation in a crime committed at age 17 along with two adult co-defendants. Juvenile Law Center’s brief argued that Miller v. Alabama and Montgomery v. Louisiana establish a presumption against imposing life without parole sentences on juveniles and requires a finding that the juvenile is permanently incorrigible and incapable of reform. Our brief further argued that the appropriate appellate standard of review for the imposition of life without parole on juveniles is plenary as an abuse of discretion standard is insufficient to ensure that sentences comply with Miller and Montgomery.
The Michigan Supreme Court held that a finding of incorrigibility is not required to impose a sentence of life without parole on a juvenile offender and that abuse of discretion is the appropriate standard of review.