Background
Kendall Thornton and accomplice Terrill Chaney were charged with the 2011 robbery and fatal shooting of Tamara Bates. Following a cold-case investigation by the Flint Police Department over a decade later, they were jointly tried. The prosecution’s evidence included text messages from 2011 in which a witness relayed that Chaney admitted the pair broke into Bates’s home seeking money and that Thornton shot a woman during the robbery, testimony from another witness that Chaney discussed the robbery and killing with him, and Thornton’s latent fingerprints (left middle finger three times, left palm once, and left little finger once) found on a garbage bag at the scene.
A jury convicted Thornton of felony-murder under MCL 750.316(1)(b), armed robbery under MCL 750.529, first-degree home invasion under MCL 750.110a(2), and three counts of felony-firearm under MCL 750.227b. The trial court, applying a fourth-offense habitual offender enhancement, sentenced him to life imprisonment without parole for felony-murder, 600 to 900 months for armed robbery, 320 months to 50 years for first-degree home invasion, and two years on each felony-firearm count.
The Court’s Holding
The Michigan Court of Appeals affirmed Thornton’s convictions, finding sufficient evidence under the deferential standard of review. The court determined that evidence was more than sufficient to establish armed robbery, first-degree home invasion, and murder: the contemporaneous 2011 text messages indicated Chaney and Thornton sought money from the victim’s home and kicked the door open; a gun was indeed stolen from the home and the door was kicked; Thornton’s fingerprints corroborated his presence; and Chaney’s admission to witness Jerod Blond that he and “KD” (Thornton’s nickname) “went and hit a lick” and “a lady was shot in the midst of the . . . lick” established the murder element.
However, the court vacated Thornton’s mandatory life-without-parole sentence for felony-murder and remanded for resentencing. The court held that binding authority from the Michigan Supreme Court’s decision in People v. Taylor (2025) extended the protections of Miller v. Alabama—which prohibits mandatory life sentences for juvenile offenders—to 19-year-old offenders. Since Thornton was 19 when he committed the offenses, his mandatory sentence violated constitutional protections against cruel and unusual punishment. The court noted that while sentencing courts retain discretion to impose life sentences, they must be able to consider lesser sentences and must weigh the “mitigating qualities of youth” in accordance with Miller and Taylor.
The court declined to address Thornton’s proportionality challenge to his 600-month armed robbery sentence, noting that the sentence was within the sentencing guidelines range and thus presumed proportional. The court left open the possibility that Thornton could raise sentencing issues on the armed robbery conviction on remand or in a subsequent appeal after resentencing on the felony-murder charge.
Key Takeaways
- Miller v. Alabama protections against mandatory life sentences now extend to 19-year-old offenders under Michigan law, not just juveniles under 18
- Circumstantial evidence—fingerprints, contemporaneous text messages, and accomplice admissions admitted under hearsay exceptions—sufficiently establishes guilt for murder, armed robbery, and home invasion when consistently pointing to guilt
- Text messages describing a crime contemporaneously admitted under the present-sense-impression hearsay exception; statements by a party-opponent offered against that party are not hearsay
- Within-guideline sentences receive a presumption of proportionality, and the court may defer ruling on proportionality challenges when a case is remanded for resentencing
Why It Matters
The Taylor decision represents a significant expansion of youth sentencing protections. By extending Miller to 19 and 20-year-olds, Michigan courts must now give all young adult offenders individualized consideration of their youth and circumstances, even in serious cases like murder. Sentencing judges can no longer impose mandatory life sentences without discretion; they must retain the ability to impose lesser sentences based on mitigating factors related to youth. This shift reflects evolving standards of decency in the criminal justice system and recognizes that young offenders may have greater potential for rehabilitation and redemption.
The case also underscores the prosecution’s ability to secure convictions in cold cases through circumstantial evidence supported by fingerprints, text messages, and witness testimony. Courts will admit text messages describing crimes under hearsay exceptions when they contemporaneously describe observed events, and accomplice statements offered against defendants are admissible as party-opponent statements, strengthening prosecutors’ ability to connect defendants to decades-old crimes.