Background
In 1976, a jury convicted Edwin Lamar Langston of first-degree felony murder for aiding and abetting an armed robbery during which Ronald Wilson fatally shot grocery-store owner Arretta Ingraham. Langston was not inside the store during the robbery or shooting. The jury was instructed that it could convict him if the murder was fairly within the scope of the criminal enterprise and might have been expected during the armed robbery. He received the then-mandatory sentence of life imprisonment without the possibility of parole.
Langston’s conviction was initially reversed on direct appeal because of the felony-murder mens rea instructions, but the Michigan Supreme Court later reinstated it after People v. Aaron limited its new definition of malice to pending and future trials. In 2020, Langston sought relief from judgment, challenging both his conviction and sentence. The trial court denied relief under existing precedent, and the Court of Appeals denied leave to appeal.
The Court’s Holding
The Michigan Supreme Court held that mandatory life without parole for a pre-Aaron felony-murder conviction is cruel or unusual punishment under the Michigan Constitution when the jury was not instructed on malice as Aaron later defined it and the prosecution cannot show beyond a reasonable doubt, based on the trial evidence, that a properly instructed jury would have found that malice. A defendant must first establish the instructional deficiency; the burden then shifts to the prosecution.
Langston established that his jury was not properly instructed on Aaron malice, but the prosecution had not yet had an opportunity to satisfy its burden. The Court therefore vacated in part the order denying postconviction relief and remanded for expedited proceedings. If the prosecution cannot meet its burden, the no-parole component of Langston’s sentence must be struck, making him eligible for parole consideration rather than guaranteeing release.
The Court left People v. Hall undisturbed for adult felony-murder defendants outside the newly defined class and declined to decide whether Aaron’s malice rule should apply retroactively to invalidate Langston’s conviction. It vacated its grant of leave on that issue and denied leave, leaving the conviction itself intact.
Key Takeaways
- A pre-Aaron felony-murder defendant must show that the jury was not instructed on intent to kill, intent to cause great bodily harm, or wanton and willful disregard of the likelihood of death or great bodily harm.
- Once that showing is made, the prosecution must prove beyond a reasonable doubt from the trial record that a properly instructed jury would have found Aaron malice.
- If the prosecution fails, the remedy is to remove the sentence’s prohibition on parole eligibility, not to vacate the conviction or order immediate release.
Why It Matters
The decision creates a postconviction pathway for people serving mandatory life without parole for Michigan felony-murder convictions obtained before Aaron, when juries could infer malice from participation in the underlying felony alone. Relief is individualized and depends on both the instructions given and the evidence presented at the original trial.
The ruling does not invalidate every pre-Aaron felony-murder sentence or broadly abolish mandatory life without parole for adult felony murder. Instead, it requires courts to determine whether the absence of an Aaron-compliant malice finding made a particular no-parole sentence constitutionally disproportionate.