People v. Poole

John Antonio Poole was sentenced to mandatory life without parole for an offense that occurred when he was 18.

Juvenile Law Center, American Civil Liberties Union of Michigan, Juvenile Sentencing Project at Quinnipiac University School of Law, and attorney Deborah Labelle filed an amicus brief in the Michigan Supreme Court in support of Mr. Poole. Our brief argued that the mandatory imposition of life without parole on an 18-year-old violates the federal and Michigan constitutions for the same reasons that the U.S. Supreme Court barred such sentences for youth under 18 in Miller v. Alabama. We further argued that there is emerging consensus in Michigan and across the country that the line between childhood and adulthood should be set above age 18.

The Michigan Supreme Court held in the companion case People v. Parks that imposing a mandatory sentence of life without parole on an 18 year old is an unconstitutionally cruel punishment under the Michigan Constitution, and that 18 year olds are entitled to the same individualized sentencing procedures as youth under 18. Pursuant to this decision, the Michigan Supreme Court remanded Mr. Poole’s case to the Michigan Court of Appeals to determine what remedies, including resentencing, are available to him. 

On remand the Court of Appeals ruled that the Michigan Supreme Court’s decision in Parks, like the U.S. Supreme Court’s decision in Montgomery, was retroactive and therefore Mr. Poole was entitled to resentencing in order for his youth to be considered.

Juvenile Law Center once again joined with the American Civil Liberties Union of Michigan and The Sentencing Project in filing an amicus brief to the Michigan Supreme Court in support of Mr. Poole and to affirm the Court of Appeals’ decision. Just as Montgomery determined that the Supreme Court’s decision in Miller must be retroactively applied for creating a new substantive rule of constitutional interpretation, amici argue that Parks has created a new substantive rule of the Michigan Constitution and accordingly the relief afforded to Mr. Parks should be extended to Mr. Poole and all others sentenced to mandatory life without parole for crimes committed when they were 18 years old.

A unanimous Michigan Supreme Court affirmed the Court of Appeals’ decision, finding that “the Parks holding is retroactive under a state retroactivity analysis.” 

LEGAL TEAM

Attorneys

Andrew Keats, Marsha Levick, Riya Saha Shah

Paralegals 

Tiffany Faith, Marissa Lariviere