Hill v. Snyder
| Decision Date | 11 May 2016 |
| Docket Number | Nos. 13–2661,13–2705.,s. 13–2661 |
| Citation | 821 F.3d 763 |
| Parties | Henry HILL; Jemal Tipton; Damion Todd; Bobby Hines ; Kevin Boyd ; Bosie Smith; Jennifer Pruitt; Matthew Bentley; Keith Maxey; Giovanni Casper; Jean Carlos Cintron; Nicole Dupure; Dontez Tillman, Plaintiffs–Appellees/Cross–Appellants, v. Rick SNYDER, in his official capacity as Governor of the State of Michigan; Daniel H. Heyns, in his official capacity as Director, Michigan Department of Corrections; Thomas R. Combs, in his official capacity as Chair, Michigan Parole Board, jointly and severally, Defendants–Appellants/Cross–Appellees. |
| Court | U.S. Court of Appeals — Sixth Circuit |
ARGUED: B. Eric Restuccia, Office of the Michigan Attorney General, Lansing, Michigan, for Appellants/Cross–Appellees. Deborah LaBelle, Ann Arbor, Michigan, for Appellees/Cross–Appellants. ON BRIEF: Margaret A. Nelson, Joseph T. Froehlich, Office of the Michigan Attorney General, Lansing, Michigan, for Appellants/Cross–Appellees. Deborah LaBelle, Ann Arbor, Michigan, Brandon J. Buskey, Steven M. Watt, Ezekiel R. Edwards, American Civil Liberties Union Foundation, New York, New York, Daniel S. Korobkin, Michael J. Steinberg, American Civil Liberties Union Fund of Michigan, Detroit, Michigan, for Appellees/Cross–Appellants.
Before: MERRITT, STRANCH, and DONALD, Circuit Judges.
This long-running case returns us to the difficult topic of juvenile crime and punishment. Our return, however, is to a new legal landscape, one defined by the Supreme Court's developing jurisprudence recognizing that the unique characteristics of youth matter in determining the propriety of their punishment. This case began when Michigan charged and tried the named plaintiffs as adults for acts they committed while under the age of 18. Each received a conviction for first-degree murder and a mandatory sentence of life in prison. Michigan laws in place at the time rendered anyone convicted of first-degree murder ineligible for parole, meaning that the plaintiffs in this case effectively received mandatory sentences of life in prison without the possibility of parole for acts they committed as children.
Plaintiffs filed suit in federal district court in 2010 challenging, among other things, the constitutionality of the Michigan statutory scheme that barred them from parole eligibility. Since that time, at least three important legal events have come to pass. First, the Supreme Court held in Miller v. Alabama, ––– U.S. ––––, 132 S.Ct. 2455, 183 L.Ed.2d 407 (2012), “that mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment's prohibition on ‘cruel and unusual punishments.’ ” Id. at 2460. Second, Michigan amended its juvenile offender laws in light of Miller, but made some of those changes contingent upon either the Michigan Supreme Court or the United States Supreme Court announcing that Miller's holding applied retroactively. See Mich. Comp. Laws Ann. §§ 769.25, 769.25a (2014). And, third, the United States Supreme Court recently held in Montgomery v. Louisiana, ––– U.S. ––––, 136 S.Ct. 718, 193 L.Ed.2d 599 (2016), that Miller's prohibition on mandatory life without parole for juvenile offenders is indeed retroactive.
The district court wisely (and presciently) reached the conclusion that Miller should apply retroactively when it ruled on the parties' cross-motions for summary judgment in 2013. That conclusion also drove the district court's issuance of an injunctive order against defendants requiring compliance with Miller. In light of the legal changes described above, however, and for the reasons that follow, we VACATE the challenged district court orders and REMAND for the district court to address these issues under the legal landscape established by Montgomery v. Louisiana, Miller v. Alabama, and this opinion.
A description of the underlying litigation—and of the intervening changes in federal and state law—is necessary to understand the current legal landscape in this case and our reasons for remanding to the district court.
In 2010, nine original plaintiffs—all of whom were juvenile offenders who had been convicted of first-degree murder under section 316 of Michigan's penal code—filed the instant lawsuit against Michigan state officials pursuant to 42 U.S.C. § 1983. Plaintiffs alleged that certain “Michigan laws, policies and practices” relevant to their sentences “violate[d] the Eighth and Fourteenth Amendments of the United States Constitution and customary international law.” Specifically, plaintiffs pointed to penal code section 316, which mandates a life sentence for anyone convicted of first-degree murder, see Mich. Comp. Laws Ann. § 750.316(1) (2010) (), and section 234 of the Michigan corrections code, which excludes those convicted under penal code section 316 from the Michigan Parole Board's jurisdiction, rendering them ineligible for parole as a matter of state law, see Mich. Comp. Laws Ann. § 791.234(6) ().
Defendants filed an answer followed by a motion to dismiss, arguing that plaintiffs' claims were procedurally barred and that they had “fail[ed] to state a claim under the Eighth Amendment's prohibition against cruel and unusual punishment, the Fourteenth Amendment's due process guarantees, [or] customary international law.” The district court granted in part and denied in part defendants' motion on July 15, 2011, holding that the applicable statutes of limitation barred all but one of the nine named plaintiffs—Keith Maxey—from seeking relief, and that Maxey had stated a claim for Eighth Amendment violations but not for violations of the Fourteenth Amendment or international law. Accordingly, the district court dismissed all of the plaintiffs' claims except for Maxey's Eighth Amendment claim. Plaintiffs filed an amended complaint in February 2012 that, as relevant here, added four new plaintiffs: Giovanni Casper, Jean Carlos Cintron, Nicole Dupure, and Dontez Tillman. All four, like Maxey, were juvenile offenders convicted of first-degree murder serving mandatory life sentences while ineligible for parole, and all four joined Maxey's Eighth Amendment challenge to Michigan's statutory scheme.
On June 25, 2012, less than six months after plaintiffs filed their amended complaint, the United States Supreme Court decided Miller v. Alabama and the landscape of this litigation shifted, recognizing the constitutional concerns raised by plaintiffs. In Miller, two 14–year–old Alabama offenders challenged the constitutionality of their mandatory sentences to life imprisonment without the possibility of parole, and the Supreme Court held for the first time “that the Eighth Amendment['s prohibition on cruel and unusual punishment] forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders.” 132 S.Ct. at 2469. The Court explained that “[b]y making youth (and all that accompanies it) irrelevant to imposition of that harshest prison sentence, such a scheme poses too great a risk of disproportionate punishment.” Id. The Court noted, moreover, that while sentencing courts were not completely foreclosed from sentencing juvenile offenders to life without parole—so long as they first considered “children's diminished culpability and heightened capacity for change” and other attendant characteristics of youth, id. —such a sentence would likely only be appropriate for “the rare juvenile offender whose crime reflects irreparable corruption.” Id. (quoting Roper v. Simmons, 543 U.S. 551, 573, 125 S.Ct. 1183, 161 L.Ed.2d 1 (2005) ).
In August 2012, two months after the Supreme Court's decision in Miller, the parties in the instant case filed cross-motions for summary judgment. Plaintiffs, relying on Miller, argued that section 234(6) of Michigan's corrections code—which barred plaintiffs from eligibility for parole—was unconstitutional as applied to juveniles and asked the court for declaratory and injunctive relief that would require Michigan to provide them with a meaningful and realistic opportunity for release. Defendants, for their part, insisted that Miller did not apply retroactively to plaintiffs and, even if it did, that the district court lacked authority to dictate the sentencing and parole procedures of the State. The district court granted-in-part and denied-in-part plaintiffs' motion and denied defendants' cross-motion in an opinion issued on January 30, 2013. Specifically, the court held that: (1) Miller applied to plaintiffs; (2) Michigan's statute barring plaintiffs from parole eligibility was unconstitutional under Miller and the Eighth Amendment; and (3) plaintiffs were entitled to some form of equitable relief from the challenged parole statute. In order to determine what form of relief was most appropriate, the court directed the parties to provide supplemental briefing addressing “the procedures that [the] court may equitably put in place to ensure that Plaintiffs receive a fair and meaningful opportunity to demonstrate that they are appropriate candidates for parole.”
It appears that defendants interpreted the district court's ruling to apply only to the named plaintiffs in the instant action and took the position that the State remained free to enforce the challenged parole statute against any other juvenile offenders convicted of first-degree murder. In response to plaintiffs' motion for clarification, the district court issued an order on August 12, 2013, stating that its January ruling declaring section 234(6) of the Michigan...
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