Michigan Supreme Court Settles Birthday Question
At what point in time does a person reach a certain age? This seemingly easy question had big implications in the case People v. Woolfolk decided by the Michigan Supreme Court today.
Deandre Woolfolk was convicted and sentenced to mandatory life without the possibility of parole for first degree murder. The murder was committed just an hour or two before his 18th birthday.
Woolfolk appealed the sentence, arguing that the U.S. Supreme Court case of Miller v. Alabama gave him the opportunity to be re-sentenced.
In the Miller case, the Court held that a juvenile (a person under 18) could not automatically be sentenced to mandatory life in prison without parole. Such a sentence violates the U.S. Constitution’s Eighth Amendment guarantee against cruel and unusual punishment.
The question for the Court here was whether Woolfolk should be considered to have been 18 at the time of the murder, seeing as how the murder so close in time to his birthday.
Under the English common law tradition, going back at least 400 years, people were considered to have reached a certain age the day before their birthday.
The Court refused to follow this tradition, citing Michigan statutes that refer to year of age by date of birth, as well as the prevailing customs of the modern age.
Ultimately, Woolfolk will be granted an opportunity for another sentencing hearing.