On Tuesday, the Michigan Supreme Court struck down life without parole sentences for a group of people convicted of felony murder before 1980. The ruling is the latest decision limiting mandatory life based on constitutional protections against cruel or unusual punishment.
The man at the center of the case, Edwin Langston, wasn’t in the store when a robber shot and killed a patron. But because a jury found he had aided the robbery, Langston was convicted of first-degree murder and received the mandatory sentence of life without parole.
He was charged under the felony murder rule, which allows prosecutors to secure a first-degree murder conviction against someone who participates in a felony that results in death, even if the person had no plan to kill, didn’t have a weapon, or wasn’t present when the killing occurred.
Langston was convicted in 1976.
In 1980, the Michigan Supreme Court limited the felony murder rule by requiring prosecutors to prove someone had malicious intent: at minimum, that they willfully disregarded the likelihood that their actions would cause a death. The court’s decision, People v. Aaron, only applied to future cases.
In Tuesday’s decision, People v. Langston, the court ruled that imposing Michigan's harshest penalty on people like Edwin Langston — whose mental state was never proven — amounted to cruel or unusual punishment.
But, the court said, the punishment was not unconstitutional in cases where the prosecution could “show beyond a reasonable doubt, on the basis of the evidence presented at trial,” that the defendant would have been convicted under today’s standard.
Eric Restuccia, with the Michigan Attorney General’s office, asked the court to establish a similar standard during oral arguments last year.
“There are some cases of just breathtaking brutality,” Restuccia said. “And the idea that those offenders have an unconstitutional sentence is just — it's an untenable conclusion.”
The attorney general’s office did not respond to a request for comment.
Court again finds conflict between mandatory life and right to proportional sentencing
Attorney Mira Edmonds, who represented Langston, said the court’s decision was in line with recent rulings requiring proportional sentencing under the state Constitution’s cruel or unusual punishment clause.
In 2025, the court ruled that the clause prohibited mandatory life sentences for people who were 20 or younger at the time of the offense, creating a pathway for many of those defendants to receive new sentences.
Edmonds told Michigan Public that while Tuesday’s ruling “is fairly narrow and affects a fairly small number of individuals, it does indicate a willingness to re-examine past injustices in sentencing and try to rectify those.”
In his lone dissent, Justice Brian Zahra wrote that Langston’s appeal did not have standing, and that the court had used his case as an “opportunity to again expand the constitutional protections afforded under Michigan’s prohibition against cruel or unusual punishment.”
Edmonds believes that fewer than 100 people will be affected by Tuesday’s ruling.
Those who can prove their mental state was never determined — like Langston, who is now 74 years old — will still have to wait to see if a prosecutor can show they would nonetheless have been convicted under the current standard for malicious intent.
If the prosecutor cannot meet that test, those people — who have been in prison for four decades or longer — will have the chance to go before a parole board and ask for release.
Advocate continues his push against mandatory life
In 1985, when Darryl Smith-Bey was 21, he and another man robbed a store in Detroit. When Smith-Bey got into a struggle with the store owner, the other man shot and killed him.
To prove Smith-Bey’s malicious intent, the prosecutor argued that he engaged in the robbery knowing his accomplice had a gun.
“That was enough to connect me with his intent to kill,” Smith-Bey said.
Now, 41 years into a life sentence for felony murder, Smith-Bey has trained as a paralegal and is among a group of advocates advancing constitutional arguments against mandatory life sentences.
Smith-Bey filed an amicus brief in last year’s landmark ruling, and he filed another in Tuesday’s decision. But because he was convicted after 1980 and was 21 when he committed the offense, neither decision applies to him.
“I'm at 63 now, so I don't have time for misery,” said Smith-Bey, who told Michigan Public he tries to find happiness in his daily life.
“And not forgetting about my victims," he said. “I know that although I'm asking for certain things, I know they can't ask for it.”
Smith-Bey said he will keep filing legal briefs, hoping that the court might one day give him a chance at freedom.
This story was produced in collaboration with the Investigative Reporting Lab at Yale.
