A word on youth and long term-of-years sentences

From the November 2025 Criminal Defense Newsletter

There were three published decisions addressing long term-of-years sentences for youthful offenders this past year, with two defendants winning relief. All three cases are pending in the Michigan Supreme Court, with one of the cases on leave-granted status. With the possibility of an upcoming decision from the Michigan Supreme Court, we provide a skeletal snapshot of the sentences and surrounding circumstances.

People v Eads: Resentencing granted for a 16-year-old defendant sentenced to 50 to 75 years imprisonment for second-degree murder. The case involved the shooting of a rival gang member and a 1992 sentencing where the defendant’s youth was not considered. The Supreme Court has granted leave.1 

People v Echols: Resentencing granted for an 18-year-old defendant sentenced to 75 to 150 years imprisonment for second-degree murder. The case involved a shooting following a dispute among passengers in a car. The defendant was sentenced in 1989, apparently without consideration of the mitigating aspects of youth. An application for leave to appeal is pending.2 

People v Nard: Resentencing denied for a 17.5-year-old defendant sentenced to 60 to 150 years imprisonment for second-degree murder. The case involved the killing of two pre-teen boys following the sexual assault of one. The defendant was first sentenced in 1975 to parolable life but was resentenced in 2023 pursuant to People v Stovall.3 He was on parole by the time of appeal. An application for leave to appeal is pending.4

Will the movement to view youth as an exceptional circumstance continue?

Endnotes
1 People v Eads, ___ Mich App ___ (2025) Docket No. 357332), leave granted 25 NW3d 118 (2025).
2 People v Echols, ___ Mich App ___ (2025) (Docket No. 370709), leave application pending.
3 People v Stovall, 510 Mich 301 (2022).
4 People v Nard, ___ Mich App ___ (2025) (Docket No. 369185), leave application pending.

Anne Yantus
Michigan Sentencing PLLC

Anne Yantus is a sentencing consultant working with attorneys to promote more favorable sentencing outcomes. Anne credits her knowledge of Michigan sentencing law to the many years she spent handling plea and sentencing appeals with the State Appellate Defender Office. Following her time with SADO, Anne taught a criminal sentencing course at the University of Detroit Mercy School of Law and subsequently continued to write and speak on felony sentencing law while serving as pro bono counsel with Bodman PLC. Anne welcomes your Michigan felony sentencing questions and is happy to arrange a consultation where appropriate. Due to the volume of inquiries, Anne is not able to respond to pro bono requests for assistance or analysis of individual fact situations.