Background
In 2015, Leandre Lamar Childs, who was 18 years old at the time of the offense, was convicted by a Wayne County jury of second-degree murder and felony-firearm. The trial court sentenced him to a mandatory consecutive two-year term for felony-firearm followed by 25 to 50 years for murder — a minimum sentence at the top of, but within, the applicable sentencing guidelines range of 180 to 300 months (or life). At sentencing, the trial court expressly acknowledged Childs’s age and his prior juvenile record, ultimately concluding he was a dangerous individual whose story was not credible.
In 2024, Childs filed a successive motion for relief from judgment, arguing that post-conviction developments in the law — particularly jurisprudence recognizing youth as a constitutionally significant mitigating factor — entitled him to resentencing. He relied principally on Miller v. Alabama, 567 US 460 (2012), and subsequent Michigan decisions including People v. Stovall, 510 Mich 301 (2022), and People v. Taylor (2025). On July 9, 2025, the Wayne Circuit Court granted the motion and ordered resentencing, finding the original sentencing court had failed to make individualized findings on youth-related mitigating factors and that the sentence was disproportionate. The prosecution appealed, and the Court of Appeals granted leave.
The trial court’s order rested on two independent grounds: entitlement to relief under MCR 6.502(G)(2) based on retroactive changes in the law, and an alternative basis under MCR 6.429 authorizing correction of an invalid sentence at any time. The trial court also characterized the sentence as effectively equivalent to those imposed on defendants serving mandatory minimum terms, and relied in part on what turned out to be a mistaken reading of the sentence actually imposed.
The Court’s Holding
The Michigan Court of Appeals reversed, finding the trial court committed multiple legal and factual errors. On the procedural side, the court held that the trial court improperly conflated the threshold gateway of MCR 6.502(G)(2) — which merely permits a successive motion to proceed — with the substantive showing required under MCR 6.508(D), which demands good cause and actual prejudice, including proof that the original sentence was invalid. The trial court granted relief without conducting the required MCR 6.508(D) analysis. The court also rejected the trial court’s alternative reliance on MCR 6.429, holding that defendants who have exhausted their appeals of right must proceed exclusively under MCR 6.500 et seq., as MCR 6.429(B)(4) expressly requires.
The Court of Appeals further found that the trial court misread the record in fundamental ways. Most critically, the trial court operated under the mistaken belief that Childs had been sentenced to a 50-year minimum, effectively doubling the actual 25-year minimum. The trial court also applied an incorrect guidelines range of 135 to 225 months, leading it to erroneously conclude the sentence exceeded the guidelines when in fact it fell within them. These factual errors infected the proportionality and constitutional analyses and independently warranted reversal.
On the merits, the court held that neither Stovall nor Taylor supported resentencing. Stovall addressed juvenile defendants sentenced to life with the possibility of parole — Childs was 18 at the time of the offense and received a term-of-years sentence, not a life sentence. Taylor addressed mandatory life without parole for 19- and 20-year-olds, which was also inapplicable. The court found no retroactive legal development that would render Childs’s 25-to-50-year sentence invalid. Because the sentence was within the guidelines range it remained presumptively proportionate, and Childs failed to demonstrate actual prejudice under MCR 6.508(D)(3)(b)(iv).
Key Takeaways
- Satisfying the procedural gateway of MCR 6.502(G)(2) to file a successive motion for relief from judgment does not automatically entitle a defendant to relief; the defendant must separately satisfy the substantive requirements of MCR 6.508(D), including good cause and actual prejudice.
- MCR 6.429 does not provide an independent path to resentencing for defendants who have exhausted their direct appeals; those defendants must proceed under the post-judgment relief rules of MCR 6.500 et seq.
- Miller v. Alabama, Stovall, and Taylor do not extend resentencing rights to adult offenders (age 18 at the time of the offense) who received term-of-years sentences within the applicable guidelines range rather than life or mandatory minimum sentences.
- A within-guidelines sentence is presumptively proportionate, and post-hoc evidence of rehabilitation and the sentencing court’s failure to explicitly articulate youth-related findings on the record do not, without more, establish that the original sentence was invalid.
Why It Matters
This decision clarifies the limits of Michigan’s expanding youthful-offender sentencing jurisprudence. While recent Michigan Supreme Court decisions have extended Miller-style individualized sentencing protections to older adolescents and imposed constitutional constraints on certain lengthy sentences, the Court of Appeals draws a firm line: those protections have not been extended retroactively to adult offenders who received within-guidelines term-of-years sentences. Defense attorneys seeking to leverage evolving case law in successive post-conviction motions must still clear the full procedural and substantive hurdles of MCR 6.508(D) — a procedural gateway alone is not enough.
The opinion also serves as a cautionary reminder about the practical consequences of factual error in post-conviction proceedings. The trial court’s misreading of the sentence imposed — treating a 25-year minimum as a 50-year minimum — fundamentally distorted its constitutional and proportionality analysis. Courts and practitioners alike must carefully verify the record before concluding that a sentence constitutes a de facto life term or exceeds applicable guidelines.