People v Langston

Michigan Supreme Court Lansing, Michigan Syllabus Chief Justice: Justices: Megan K. Cavanagh Brian K. Zahra Richard H. Bernstein Elizabeth M. Welch Kyra H. Bolden Kimberly A. Thomas Noah P. Hood This syllabus constitutes no part of the opinion of the Court but has been Reporter of Decisions: prepared by the Reporter of Decisions for the convenience of the reader. Kimberly K. Muschong PEOPLE v LANGSTON Docket No. 163968. Argued December 10, 2025 (Calendar No. 1). Decided July 28, 2026. In 1976, a jury convicted defendant, Edwin L. Langston, of first-degree felony murder for aiding and abetting an armed robbery and fatal shooting carried out by Ronald Wilson at a grocery store. Defendant was sentenced to life in prison without the possibility of parole (LWOP). Defendant’s conviction was initially reversed on direct appeal on the basis that the trial court had improperly instructed the jury on the mens rea requirement of felony murder. 86 Mich App 656 (1978), rev’d 320 NW2d 53 (1982). The prosecution’s application for leave to appeal this decision was held in abeyance for People v Aaron, 409 Mich 672 (1980), which ultimately held that the element of malice required to convict a defendant of felony murder must be established by proof of intent to kill, intent to cause great bodily harm, or wanton and willful disregard of the likelihood that the natural tendency of one’s behavior is to cause death or great bodily harm. However, the Aaron Court specified that its decision would apply only to trials in progress and those occurring after the date of the opinion. Following Aaron, the Supreme Court reversed the Court of Appeals judgment and reinstated defendant’s first-degree murder conviction, citing the part of Aaron that limited its holding to prospective application. 320 NW2d 53 (1982). The case eventually returned to the Court of Appeals to consider additional arguments that had been raised on direct appeal. The Court of Appeals affirmed defendant’s conviction in an unpublished per curiam opinion, issued May 4, 1988 (Docket No. 95650), and the Supreme Court denied leave to appeal, 431 Mich 911 (1988). In 2020, defendant moved for relief from judgment, arguing that his conviction must be vacated because the prosecution had not proved malice as required by Aaron and that his sentence of LWOP constituted cruel or unusual punishment. The trial court, Kathleen M. Brickley, J., denied the motion because it was constrained by the holding in Aaron that it had no retroactive effect and the holding in People v Hall, 396 Mich 650 (1976), that the imposition of mandatory LWOP for felony murder was not unconstitutionally cruel or unusual. Defendant sought leave to appeal, which the Court of Appeals denied. Defendant then applied for leave to appeal in the Supreme Court, which directed oral argument on the application. 513 Mich 1118 (2024). Following oral argument and subsequent supplemental briefing on the sentencing issue, the Supreme Court granted defendant’s application for leave to appeal and directed the parties to address six issues: (1) whether Aaron correctly limited its application to prospective-only relief; (2) whether, in the absence of evidence that the defendant acted with malice, mandatory LWOP for felony murder constitutes cruel and/or unusual punishment under Const 1963, art 1, § 16 or US Const, Am VIII; (3) whether Hall should be overruled; (4) whether a mandatory sentence of LWOP for felony murder is cruel and/or unusual punishment in all cases decided before Aaron or only in those pre-Aaron cases where overwhelming evidence of malice was not otherwise presented at trial; (5) if the latter, the standard by which the courts should determine whether sufficient evidence of malice was presented and the means by which a defendant should present such an argument; and (6) what remedy is required if any defendants’ sentences of LWOP are found invalid. ___ Mich ___, ___; 18 NW3d 296, 296-297 (2025). In an opinion by Justice BOLDEN, joined by Justices BERNSTEIN, WELCH, and HOOD, the Supreme Court held: The imposition of mandatory LWOP for pre-Aaron felony-murder convictions constitutes cruel or unusual punishment under Article 1, § 16 of the Michigan Constitution if two conditions are met. The defendant must first establish that the jury was not instructed on malice as defined by Aaron. If so established, the burden shifts to the prosecution to show beyond a reasonable doubt, on the basis of the evidence presented at trial, that a jury would have found that the defendant acted with malice as defined by Aaron had it been so instructed. If the prosecution cannot meet its burden, the remedy is to strike the no-parole aspect of the LWOP sentence, which would render any defendant who qualifies eligible for parole consideration. 1. Defendant met his burden to establish good cause for filing his motion for relief from judgment under MCR 6.508(D)(3) because the legal basis for his sentencing argument was not reasonably available on direct appeal. Shortly before defendant’s conviction, Hall held that mandatory LWOP for felony murder did not constitute cruel or unusual punishment under the proportionality test from People v Lorentzen, 387 Mich 167 (1972). Throughout the pendency of his direct appeal, constitutional sentencing law under Const 1963, art 1, § 16 remained largely static. However, beginning in 2010, a series of United States Supreme Court decisions imposed new constitutional limitations on mandatory LWOP sentences for juvenile offenders, and the Michigan Supreme Court expanded on the protections set forth in those cases to hold that mandatory LWOP for offenders under 21 years old violates Michigan’s prohibition on cruel or unusual punishment, marking a consistent trend away from the mandatory imposition of LWOP for first-degree murder when that punishment is not tailored to a defendant’s personal responsibility and moral guilt. These developments in precedent established good cause under MCR 6.508(D) because they provided a reasonable legal basis for the cruel-or-unusual- punishment argument that did not exist at the time of defendant’s prior appeals. 2. To determine whether a punishment is cruel or unusual, Michigan courts consider the factors in Lorentzen and People v Bullock, 440 Mich 15 (1992): (1) the severity of the sentence relative to the gravity of the offense, (2) sentences imposed in the same jurisdiction for other offenses, (3) sentences imposed in other jurisdictions for the same offense, and (4) the goal of rehabilitation. First, imposing LWOP, the most severe sentence available in Michigan, is grossly disproportionate to the gravity of the offense where a jury made no finding that a defendant acted with malice as defined by Aaron and the prosecution cannot establish beyond a reasonable doubt that such malice would have otherwise been found. Second, mandatory LWOP is imposed for first-degree murder, habitual first-degree criminal sexual conduct against a child under 13, and a few other offenses resulting in death, including crimes that require proof of intent akin to malice. The nature of these crimes reflects the Legislature’s determination that Michigan’s use of mandatory LWOP should be reserved for those whose criminal culpability mandates automatic, permanent removal from society, as contrasted with those who caused an unforeseen or accidental death. Third, Michigan is among a small number of states that mandate LWOP for felony murder. And finally, mandatory imposition of LWOP forecloses the possibility of release and therefore does not further the goal of rehabilitation. Accordingly, the imposition of mandatory LWOP for pre-Aaron felony-murder convictions is constitutionally impermissible cruel or unusual punishment where the jury made no finding of malice as defined by Aaron, unless the prosecution can show beyond a reasonable doubt, on the basis of the evidence presented at trial, that the jury would have found such malice had it been so instructed. 3. To obtain relief from a sentence of LWOP for a pre-Aaron felony-murder conviction, in keeping with MCR 6.508(D), the defendant has the initial burden to establish that the jury was not instructed on—and thus made no finding on—malice as defined by Aaron. If a defendant makes this showing, the burden shifts to the prosecution to establish beyond a reasonable doubt that the jury would have found that the defendant acted with such malice on the basis of the evidence presented at trial. If a defendant succeeds in establishing that their sentence was invalid, the remedy is to strike the element of their sentence that eliminates the possibility of parole. 4. The holding in Hall that Const 1963, art 1, § 16 permits a mandatory punishment of LWOP for felony murder was left undisturbed to the extent it applies to a defendant who was at least 21 years old at the time of the offense and not within the class of offenders entitled to relief pursuant to the framework in this opinion, because the question whether mandatory LWOP for felony murder is unconstitutional in all its applications was not before the Court. 5. Defendant’s jury was not instructed that it could find malice by intent to kill or cause great bodily harm. The closest the instructions came to articulating Aaron-like malice was that the jury could find him guilty of felony murder if the murder was fairly within the scope of a criminal enterprise and might have been expected to happen in the course of committing the robbery with a pistol, but a significant gap existed between this instruction and the “wanton and willful” formulation of malice, and the instruction did not require the jury to find that defendant should have known that a murder might occur. Establishing that a person acted with a “wanton and willful disregard of the likelihood that the natural tendency of defendant’s behavior is to cause death or great bodily harm” presents a heavier burden of proof of intent, akin to criminal gross negligence. As the Court of Appeals originally held on direct appeal, defendant has shown that his jury was not instructed on malice as later defined in Aaron. Accordingly, the burden has shifted to the prosecution to prove beyond a reasonable doubt that a rational jury would have found that defendant acted with malice as defined by Aaron had it been so instructed. The prosecution has not yet had an opportunity to meet this burden, so the trial court order denying sentencing relief was vacated in part and the case was remanded for further proceedings. 6. The order granting defendant leave to appeal was vacated in part as to the question whether Aaron correctly limited its application to prospective-only relief, and leave was denied with respect to that issue.  Trial court order vacated in part and case remanded to the trial court for expedited further proceedings. Chief Justice CAVANAGH, concurring in part and dissenting in part, agreed that defendant showed good cause as required under MCR 6.508(D)(3)(a) and that an LWOP sentence imposed for a felony-murder conviction where a jury made no finding of malice as the term was defined in Aaron is grossly disproportionate and thus invalid for purposes of the “actual prejudice” requirement of MCR 6.508(D)(3)(b)(iv). However, she disagreed with the majority’s remedy, stating that she would have struck the no-parole aspect of defendant’s sentence and ordered that he be resentenced to life with the possibility of parole in accordance with the remedy applied in People v Bullock, 440 Mich 15 (1992). She explained that she was not persuaded by the majority’s turn to the harmless-error standard as it applies in instances where a jury instruction is omitted, given that defendant’s conviction was based on a jury finding beyond a reasonable doubt with respect to all the elements required at that time, and she stated that application of the harmless- error doctrine was unfair in this situation because a defendant who did not know that this iteration of malice was an element of the crime had no motivation to dispute malice or put forth evidence in opposition to evidence that would support a finding of malice. Because Bullock provides a workable remedy, she would not have searched other areas of the law, including the harmless- error standard of review applicable to jury instruction omissions or Eighth Amendment capital- sentencing jurisprudence, to create a new and unnecessary framework. Justice ZAHRA, dissenting, would have held that defendant was not entitled to relief because the Supreme Court expressly concluded that Aaron should have prospective effect only and because defendant failed to establish good cause under MCR Subchapter 6.500. He explained that a judgment of conviction and sentence that has survived direct review is entitled to a strong presumption of finality, noting that the state’s interest in closing disputes is at its highest when the state invokes its power to adjudge guilt and impose punishment in a criminal proceeding. He stated that finality is not a mere technicality, but a core value of the criminal justice system upon which the legitimacy of the criminal law depends. While he acknowledged that the state’s commitment to finality in criminal jurisprudence is not absolute, he concluded that defendant failed to establish a right to relief under the narrow exceptions to finality provided under Michigan’s court rules. Justice THOMAS did not participate because of her prior involvement in this case.  Michigan Supreme Court Lansing, Michigan OPINION Chief Justice: Justices: Megan K. Cavanagh Brian K. Zahra Richard H. Bernstein Elizabeth M. Welch Kyra H. Bolden Kimberly A. Thomas Noah P. Hood FILED July 28, 2026 STATE OF MICHIGAN SUPREME COURT PEOPLE OF THE STATE OF MICHIGAN, Plaintiff-Appellee, v No. 163968 EDWIN LAMAR LANGSTON, Defendant-Appellant. BEFORE THE ENTIRE BENCH (except THOMAS, J.) BOLDEN, J. In People v Aaron, 409 Mich 672, 728; 299 NW2d 304 (1980), this Court held that the element of malice required to convict a defendant of felony murder must be established by proof of intent to kill, intent to cause great bodily harm, or wanton and willful disregard of the likelihood that the natural tendency of one’s behavior is to cause death or great bodily harm. The Aaron Court concluded, however, that its decision would not apply retroactively to trials already completed. Id. at 734. As a result, this Court upheld the pre-Aaron felony- murder conviction of defendant, Edwin Lamar Langston, who was found guilty in 1976 and sentenced to the legislatively mandated penalty of life imprisonment without the possibility of parole (LWOP). Langston asks us to revisit the lawfulness of his conviction and sentence. With respect to the sentence, we consider whether mandatory LWOP violates the Michigan Constitution’s ban on “cruel or unusual” punishment where a jury never found that the defendant intended to kill, intended to cause great bodily harm, or wantonly and willfully disregarded the likelihood that the natural tendency of their behavior was to cause death or great bodily harm. Const 1963, art 1, § 16. Put differently, if a jury made no finding that a defendant exhibited malice as defined by Aaron, is mandatory LWOP a constitutionally permissible sentence? We hold that mandatory LWOP for pre-Aaron felony murder constitutes cruel or unusual punishment under Article 1, § 16 of the Michigan Constitution if two conditions are met. The defendant must first establish that the jury was not instructed on malice as defined by Aaron. If so established, the burden shifts to the prosecution to show beyond a reasonable doubt, on the basis of the evidence presented at trial, that a jury would have found that the defendant acted with such malice had it been instructed in accordance with Aaron. If the prosecution cannot meet its burden, the defendant is entitled to relief. We also conclude that the constitutionally permissible remedy is to strike the portion of the sentence prohibiting parole eligibility, which would make any qualifying defendant eligible for parole consideration. As applied here, Langston has established that the jury in his case was not instructed on malice as defined by Aaron. But the prosecution has not yet had an opportunity to meet 2 its burden under the test we announce today. We therefore vacate in part the trial court’s order denying relief from judgment and remand to that court for further proceedings consistent with this opinion. 1 I. AARON AND THE DOCTRINE OF FELONY MURDER Central to this case is the doctrine of felony murder and the culpability of those convicted of this offense before Aaron. In Michigan, first-degree felony murder is a killing with malice that occurs during the commission of an enumerated felony. People v Nowack, 462 Mich 392, 401; 614 NW2d 78 (2000); MCL 750.316(1)(b). Proof of malice separates all forms of murder, including felony murder, from manslaughter. People v Mendoza, 468 Mich 527, 533-534; 664 NW2d 685 (2003). At common law, malice for purposes of felony murder could be shown by proving intent to commit the underlying felony alone. See Aaron, 409 Mich at 689-698 (discussing the origins of the felony-murder doctrine). This common-law rule thus equally punished “all homicides, committed in the perpetration or attempted perpetration of proscribed felonies whether intentional, unintentional or accidental, without the necessity of proving the relation between the homicide and the perpetrator’s state of mind.” Id. at 708. In Aaron, the Court considered whether to modify the requirements for proving malice to obtain a conviction in felony-murder cases. Initially, because the common law 1 We also vacate the portion of our order granting leave to appeal as to the issue of whether Aaron correctly limited its application to prospective relief only and now deny leave to appeal on that issue because we are no longer persuaded that the question presented should be reviewed by this Court. In other words, we decline to address Langston’s challenge to his felony-murder conviction, so we do not disturb the portion of the trial court’s order denying relief on this issue. 3 continues to prevail in Michigan unless abrogated by the Constitution, the Legislature, or this Court, Aaron concluded that the common-law doctrine remained the law in the state. Id. at 722-723. The Court explained, however, that the doctrine violates a core principle of criminal law—that determinations of guilt should be based on individual culpability. Id. at 708. Relevant to cases involving multiple offenders, Aaron recognized that “hold[ing] one felon liable for the unforeseen and unagreed-to results of another felon” is fundamentally unfair. Id. at 731. After discussing Michigan caselaw that further undermined the justification for the doctrine, id. at 723-727, the Court deemed it appropriate to “abolish the rule which defines malice as the intent to commit the underlying felony,” id. at 727. The Court then announced the definition of malice that remains today: “[M]alice is the intention to kill, the intention to do great bodily harm, or the wanton and willful disregard of the likelihood that the natural tendency of defendant’s behavior is to cause death or great bodily harm.” Id. at 728. “If the jury concludes that malice existed, they can find murder and, if they determine that the murder occurred in the perpetration or attempted perpetration of one of the enumerated felonies, by statute the murder would become first-degree murder.” Id. at 730. In closing, the Court summarily decided that its holding applied only to the parties at issue, as well as to “all trials in progress and those occurring after the date of this opinion.” Id. at 734. 2 2 The Court later made an exception in People v Wilder, 411 Mich 328, 337; 308 NW2d 112 (1981), overruled in part on other grounds by People v Ream, 481 Mich 223 (2008). While Wilder was not argued together with Aaron, the Court had granted leave in Wilder on the same day as it did in Aaron. Id. Because Wilder essentially raised an identical issue to that raised in Aaron, the Court treated Wilder as a companion case for purposes of applying the rule announced in Aaron. Id. After deciding Wilder, the Court also granted relief to that defendant’s codefendant. People v Butts, 411 Mich 1041 (1981). 4  First-degree felony murder remains a crime in Michigan, MCL 750.316(1)(b), but Aaron clarified the necessary intent to prove it. It held that the circumstances of the underlying felony remain relevant, as does the fact that a death occurred during a felony, and it also held that a jury may properly infer malice from the nature of the felony and the facts surrounding its commission. Aaron, 409 Mich at 728-730. But “the jury may not find malice [to commit the murder] from the intent to commit the underlying felony alone.” Id. at 730. Therefore, since Aaron, to prove the element of malice for felony murder, the prosecution must show beyond a reasonable doubt that the defendant “intended to kill, intended to cause great bodily harm, or wantonly and willfully disregarded the likelihood that the natural tendency of his behavior was to cause death or great bodily harm.” People v Riley (After Remand), 468 Mich 135, 140-141; 659 NW2d 611 (2003). II. FACTUAL BACKGROUND AND PROCEDURAL HISTORY In 1976, a jury convicted Langston of first-degree felony murder for his role in aiding and abetting an armed robbery and shooting carried out by Ronald Wilson. The crime occurred when Wilson robbed a grocery store and fatally shot one of the store’s owners, Arretta Ingraham. Langston had previously gone inside the store while Wilson stayed in his car. Then, when Langston returned to the car, Wilson asked how many people were inside, and Langston told him that two women and two children were in the store. Langston claimed that he wanted no involvement in a robbery, so he took the car and drove up the street while Wilson went inside the store, committed a robbery, and fatally shot a victim. It is undisputed that Langston was not present in the store during the robbery or shooting. After the killing, Wilson exited the store and ran up the street, and he and 5 Langston ultimately left the area in Wilson’s car. The prosecution presented additional evidence that Langston met with Wilson later that night and discussed burning a wallet that Wilson stole during the robbery. Langston was charged with first-degree felony murder on an aiding-and-abetting theory. 3 The trial court instructed the jury that in order to convict Langston, it first had to find Wilson guilty of felony murder beyond a reasonable doubt. To do so, the jury had to find that Wilson either “intended to kill” the victim or “consciously engaged in committing a serious crime, robbery, using a pistol which was naturally and inherently dangerous to human life in the manner of which that crime of robbery was committed[.]” The trial court later instructed the jury on the elements that it had to find were established to convict Langston as an aider and abettor: First, that the defendant intended to commit the crime of robbery at the time that he allegedly aided and abetted or encouraged Ronald Wilson; Second, that the defendant performed acts or gave encouragement which in fact did aid, or abet, or assist in the commission of the crime of robbery; Third, that the crime of murder occurred as a result of this robbery; Fourth, that this murder which occurred was fairly within the scope of a criminal enterprise and it might have been expected to happen in the course of committing this robbery with a pistol. 3 Wilson was tried separately and convicted of first-degree felony murder. See People v Wilson, 84 Mich App 636; 270 NW2d 473 (1978). On direct appeal, the Court of Appeals reversed his conviction and remanded for entry of a judgment of conviction on the lesser included offense of manslaughter and for resentencing. Id. at 638. After its decision in Aaron, this Court reversed the Court of Appeals judgment and reinstated Wilson’s felony- murder conviction. People v Wilson, 411 Mich 990 (1981). 6 The jury was also instructed on the lesser included offenses of second-degree murder and manslaughter. Langston was convicted of first-degree felony murder, and the trial court sentenced him to mandatory LWOP. 4 A series of procedural oddities followed on direct appeal. Langston argued in the Court of Appeals that the trial court improperly instructed the jury on the mens rea requirement of felony murder. The Court of Appeals agreed, so it reversed the conviction and remanded for a new trial. People v Langston, 86 Mich App 656, 660; 273 NW2d 99 (1978), rev’d 320 NW2d 53 (1982). The panel held: “Although the record contains facts from which an inference of malice might have been drawn (i.e., aiding an armed robbery itself creates a risk of death), the issue must be retried and put before the jury.” Id. at 661. The prosecution filed an application for leave to appeal, which this Court held in abeyance for Aaron. Following the decision in Aaron, this Court initially denied the prosecution’s application. People v Langston, 412 Mich 903 (1982). But the prosecution moved for reconsideration, and this Court granted the request, reversed the judgment of the Court of Appeals, and reinstated Langston’s first-degree murder conviction. People v Langston, 4 At the time of Langston’s conviction, Michigan’s first-degree murder statute provided: All murder which shall be perpetrated by means of poison, or lying in wait, or any other kind of wilful, deliberate and premeditated killing, or which shall be committed in the perpetration, or attempt to perpetrate any arson, rape, robbery, burglary, larceny of any kind, extortion or kidnapping, shall be murder of the first degree, and shall be punished by solitary confinement at hard labor in the state prison for life. [MCL 750.316, as amended by 1969 PA 331.] 7 320 NW2d 53 (1982). 5 In reinstating the conviction, this Court cited the portion of Aaron that limited its holding to prospective application. Id., citing Aaron, 409 Mich at 734. In other words, although the Court of Appeals’ holding in Langston was similar to the conclusion reached in Aaron, this Court reversed the Court of Appeals on the basis that Aaron applied only to trials in progress and those occurring thereafter. The case eventually returned to the Court of Appeals to consider additional arguments that had been raised on direct appeal. The Court of Appeals affirmed the conviction, and this Court denied leave to appeal. People v Langston, unpublished per curiam opinion of the Court of Appeals, issued May 4, 1988 (Docket No. 95650); People v Langston, 431 Mich 911 (1988). Langston claims that he filed a motion for relief from judgment in 1992, which was denied. He attempted to file another motion for relief from judgment in 2003. Because that motion failed to comply with procedural filing requirements, the trial court returned the submission without filing it. In 2020, with the assistance of counsel, Langston filed the motion for relief from judgment at issue here. Relying on Aaron, he argued that his conviction must be vacated. He contended that the Aaron Court interpreted the first-degree murder statute to require malice; therefore, the prosecution never proved an essential element of the crime for which he was convicted, in violation of due process. Langston also challenged his sentence, arguing that mandatory LWOP for pre-Aaron felony-murder convictions obtained without 5 This Court’s order—which was not published in the Michigan Reports, notwithstanding a citation of “413 Mich 911” in the North Western Reporter—noted that the earlier order denying leave to appeal was entered “as a result of clerical error.” Id. at 53. 8 proven mens rea constituted either “cruel and unusual” or “cruel or unusual” punishment under the United States and Michigan Constitutions, respectively. The trial court issued an opinion and order denying the motion for relief from judgment because it was “constrained to follow established precedent . . . .” Langston’s challenge to his conviction lacked merit, the trial court concluded, because Aaron held that its opinion had no retroactive effect. Similarly, with respect to Langston’s challenge to his LWOP sentence, the trial court explained that it was bound by People v Hall, 396 Mich 650; 242 NW2d 377 (1976), to reject the argument. Still, the trial court noted that jurisprudence in Michigan had evolved significantly in the nearly 50 years since Hall, so the case was “ripe for review” by this Court. Langston sought leave to appeal, which the Court of Appeals denied. People v Langston, unpublished order of the Court of Appeals, entered December 2, 2021 (Docket No. 358537). Langston then applied for leave to appeal in this Court. We directed oral argument on the application. People v Langston, 513 Mich 1118 (2024). Following oral argument in January 2025, we requested and received supplemental briefing on the sentencing issue. People v Langston, ___ Mich ___; 15 NW3d 820 (2025). Upon further consideration, we granted Langston’s application for leave to appeal and directed the parties to address six issues: (1) whether People v Aaron, 409 Mich 672 (1980), correctly limited its application to prospective-only relief; (2) whether, in the absence of evidence that the defendant acted with malice, mandatory life without parole for felony murder constitutes cruel and/or unusual punishment under Const 1963, art 1, § 16 or US Const, Am VIII; (3) whether People v Hall, 396 Mich 650 (1976), should be overruled; (4) whether a mandatory sentence of life imprisonment without parole for felony murder is cruel and/or unusual punishment under Const 1963, art 1, § 16 or US Const, Am VIII, in all cases decided before 9  Aaron, supra, where the jury was not required to make a finding of malice, or only in those pre-Aaron cases where overwhelming evidence of malice was not otherwise presented at trial; (5) if the latter, the standard by which the courts should determine whether sufficient evidence of malice was presented and the means by which a defendant should present such an argument; and (6) what remedy is required if any defendants’ sentences of mandatory life imprisonment without parole are found invalid. [People v Langston, ___ Mich ___, ___; 18 NW3d 296, 296-297 (2025).] We turn to our discussion of the sentencing issues. 6 III. GOOD CAUSE UNDER MCR 6.508(D) The filing of a motion for relief from judgment under MCR Subchapter 6.500 is generally the exclusive means to challenge a criminal conviction or sentence that is no longer subject to direct appeal. See MCR 6.501. And after August 1, 1995, with several exceptions, only one motion for relief from judgment may be filed with respect to a conviction. MCR 6.502(G)(1) and (2). 7 A defendant who files such a motion has the burden to establish entitlement to relief. MCR 6.508(D). Relief is generally barred if the motion raises an issue that was previously decided against the defendant. MCR 6.508(D)(2). 8 Similarly, if the motion alleges grounds for relief that could have been raised 6 As noted earlier, we vacate our grant of leave to appeal on the first issue and now deny leave with respect to that issue. Thus, contrary to Justice ZAHRA’s view, we do not, “effectively” or otherwise, apply the decision in Aaron retroactively. Our opinion simply does not address the issue. 7 The trial court correctly determined that the procedural bar on successive motions does not apply here because this is Langston’s first motion filed after August 1, 1995. See MCR 6.502(G)(1). Because the 2003 motion was returned by the trial court without filing, it does not count toward the successive-motion bar. See MCR 6.502(D); People v Starnes, 505 Mich 1052, 1052 (2020). 8 We agree with the trial court that relief is not barred under MCR 6.508(D)(2). While Langston claims to have filed a motion for relief from judgment in propria persona in 1992, nothing in the register of actions or the lower court record corroborates that any submission was made. The trial court’s opinion in this case states that the 1992 filing and 10 on direct appeal or in a prior motion for relief from judgment (but were not), a court may not grant the motion unless the defendant shows “good cause” for this failure and “actual prejudice” from the alleged irregularities. MCR 6.508(D)(3). Langston argues that he has good cause for raising his sentencing challenge now because the caselaw on which he relies was not available at the time of his direct appeal. “Good cause” can be established “by showing that some external factor prevented counsel from previously raising the issue.” People v Reed, 449 Mich 375, 378; 535 NW2d 496 (1995). External factors include “ ‘showing that the factual or legal basis for a claim was not reasonably available to counsel . . . .’ ” Id. at 385 n 8, quoting Murray v Carrier, 477 US 478, 488; 106 S Ct 2639; 91 L Ed 2d 397 (1986). We conclude that Langston has met his burden to establish good cause because the legal basis for his sentencing argument was not reasonably available on direct appeal or for decades to come. Shortly before Langston’s conviction, this Court held in Hall, 396 Mich at 657-658, that mandatory LWOP for felony murder did not constitute cruel or unusual punishment under the proportionality test from People v Lorentzen, 387 Mich 167; 194 NW2d 827 the order denying the motion “have since been lost,” but it is unclear whether the trial court was able to otherwise verify that a motion for relief from judgment was filed in the first place. Assuming a motion was in fact filed in 1992, there is nothing in the record to suggest that this motion raised the same constitutional sentencing issue that is raised here, and the prosecution does not argue as much. We therefore accept as uncontested by the parties that this issue has never been decided against Langston in a prior proceeding. Nonetheless, Justice ZAHRA suggests that Langston’s current sentencing challenge is a mere “repackaged attack on the validity of his conviction” that this Court rejected when we reinstated his conviction on direct appeal in 1982. See Langston, 320 NW2d at 53. That argument stretches the scope of MCR 6.508(D)(2) beyond its plain language. Nothing in this Court’s 1982 order addressed a constitutional sentencing challenge, nor had one been raised by Langston on direct appeal. 11 (1972). Throughout the pendency of his direct appeal, which extended more than 10 years, constitutional sentencing law under Const 1963, art 1, § 16 remained largely static. Therefore, tenable legal grounds did not exist on direct appeal to bring this current sentencing challenge. 9 But significant jurisprudential developments in constitutional sentencing law have since occurred. Beginning in 2010, a series of United States Supreme Court decisions imposed new constitutional limitations on mandatory LWOP sentences for juvenile offenders. First, the Court held that sentencing a juvenile to LWOP for a nonhomicide offense violates the Eighth Amendment’s prohibition of “cruel and unusual” punishments. Graham v Florida, 560 US 48, 82; 130 S Ct 2011; 176 L Ed 2d 825 (2010). Soon after, the Court held that the same constitutional infirmity exists with the imposition of mandatory LWOP for juveniles convicted of homicide. Miller v Alabama, 567 US 460, 465; 132 S Ct 2455; 183 L Ed 2d 407 (2012). The Court later held that its decision in Miller applies retroactively to cases on collateral review. Montgomery v Louisiana, 577 US 190, 206; 136 S Ct 718; 193 L Ed 2d 599 (2016). Although published after the instant motion was filed, this Court has expanded on the protections set forth in Graham and Miller in cases holding that mandatory LWOP for offenders under 21 years old violates Michigan’s prohibition on “cruel or unusual” punishment. People v Parks, 510 Mich 225, 9 We would reach the same conclusion even if we assumed that Langston had filed a motion for relief from judgment in 1992. At that time, there had been no precedential changes regarding the permissibility of mandatory LWOP as punishment for felony murder under Michigan’s cruel-or-unusual-punishment clause. 12 266; 987 NW2d 161 (2022); People v Taylor, ___ Mich ___, ___; ___ NW3d ___ (April 10, 2025) (Docket No. 166428); slip op at 2. 10 While these cited cases are not dispositive of the issue before us, 11 they mark a c