Michigan v. Taylor (Opinion on Application - Remand to CoA)
Annotate this CaseRobert Taylor was convicted by jury of first degree felony murder, carjacking, conspiracy to commit carjacking, kidnapping conspiracy to commit kidnapping, and possession of a firearm during the commission of a felony. In 2009, defendant and his codefendant, Ihab Masalmani, abducted Matt Landry from outside a sandwich shop. Defendant acted as the lookout while Masalmani forced Landry into Landry’s car. The two then drove Landry away at gunpoint. Defendant and Masalmani held Landry against his will for several hours and stole money from his bank account during that time; Landry was later killed by a gunshot wound to the head. Defendant was sentenced to a mandatory term of life in prison without the possibility of parole (LWOP). The issue this case presented for the Michigan Supreme Court’s review provided an opportunity for the Court to provide “much-needed” guidance to criminal defendants, prosecutors, and trial courts on the proper procedure for conducting MCL 769.25 sentencing hearings when a prosecutor seeks to impose a sentence of life without parole (LWOP) for a crime committed when the defendant was a juvenile. The Court held that, as the moving party at a Miller hearing, the prosecutor bears the burden to rebut a presumption that LWOP is a disproportionate sentence under the clear and convincing standard. In this case, the trial court was not operating within the framework the Supreme Court set forth here. Defendant was therefore entitled to resentencing. Because the Court of Appeals failed to address a separate constitutional issue that could be dispositive, however, the Supreme Court remanded this case to the Court of Appeals to consider that issue in the first instance before any resentencing can take place.
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