The Michigan Supreme Court ruled on July 28, 2026, that mandatory life sentences without the possibility of parole (LWOP) for felony murder may violate the state constitution if the jury did not find that the defendant acted with malice. This ruling affects individuals convicted of felony murder before a significant 1980 legal decision that clarified the definition of malice in such cases.
The case, People v. Langston (Docket No. 163968), revolves around Edwin L. Langston, who was convicted in 1976 for his role in a robbery that led to a fatal shooting. The court's decision could impact numerous defendants who received similar sentences under the previous legal framework.
Langston's conviction stemmed from an armed robbery where he aided Ronald Wilson, who shot a grocery store owner during the crime. Initially sentenced to life in prison without parole, Langston's conviction faced various legal challenges over the years, particularly regarding the jury's instructions on malice. In 1980, the Michigan Supreme Court ruled in People v. Aaron that malice must be proven for felony murder convictions, but this ruling was not applied retroactively.
In 2020, Langston filed a motion for relief from judgment, arguing that his conviction should be vacated because the prosecution failed to prove malice as required under the Aaron decision. He also contended that his LWOP sentence constituted cruel or unusual punishment under both the Michigan and U.S. constitutions. The trial court denied his motion, citing the precedent set by Aaron, which limited its application to future cases.
Langston appealed this decision, and the Michigan Supreme Court agreed to hear the case. The court's ruling, delivered by Justice Kyra H. Bolden, stated that mandatory LWOP for felony murder convictions prior to Aaron could be considered cruel or unusual punishment if two conditions were met. First, the defendant must show that the jury was not instructed on malice as defined by Aaron. If this is established, the burden then shifts to the prosecution to prove beyond a reasonable doubt that a jury would have found malice if properly instructed.
Justice Bolden emphasized, "The imposition of mandatory LWOP for pre-Aaron felony-murder convictions constitutes cruel or unusual punishment under Article 1, § 16 of the Michigan Constitution if two conditions are met." The court determined that if the prosecution cannot meet this burden, the remedy would be to strike the no-parole aspect of the LWOP sentence, allowing the defendant eligibility for parole consideration.
The court's decision also noted the evolving legal landscape regarding mandatory LWOP sentences, particularly in light of U.S. Supreme Court rulings that have imposed limitations on such sentences for juvenile offenders. The Michigan Supreme Court has previously expanded these protections to include offenders under 21 years old.
Chief Justice Megan K. Cavanagh concurred in part but dissented regarding the remedy, advocating for a different approach to addressing the sentencing issue. Justice Brian K. Zahra dissented, arguing that the court should not grant relief based on the precedent established in Aaron.
This ruling could have significant implications for Langston and others in similar situations, as it opens the door for potential re-evaluation of their sentences if they can demonstrate that malice was not proven during their trials. The court's decision marks a shift in how Michigan law may treat past felony murder convictions, particularly those lacking a clear finding of malice.
Moving forward, defendants previously sentenced to LWOP for felony murder may seek relief under this new framework. The court's ruling does not appear to have a direct path for appeal, but it does set a precedent that could influence future cases involving similar legal questions.