People of Michigan v. Stanley Lewis Gibbs

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports. STATE OF MICHIGAN COURT OF APPEALS PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED June 10, 2025 Plaintiff-Appellee, 1:47 PM v No. 355399 Genesee Circuit Court STANLEY LEWIS GIBBS, LC No. 80-029659-FC Defendant-Appellant. Before: YATES, P.J., and YOUNG and WALLACE, JJ. PER CURIAM. Defendant was 18 years old when he broke into a house and participated in killing the victim. A jury convicted defendant of first-degree felony murder in 1980, and the trial court sentenced him to a mandatory term of life imprisonment without the possibility of parole (LWOP). Because defendant was 18 years old when he committed the offense, his mandatory LWOP sentence is now considered unconstitutional as cruel or unusual punishment under prevailing caselaw, and the prosecution agrees that defendant is entitled to resentencing. See People v Poole, ___ Mich ___; ___ NW3d ___ (2025) (Docket No. 166813); slip op at 1; People v Parks, 510 Mich 225, 232; 987 NW2d 161 (2022). Therefore, we vacate defendant’s sentence and remand for resentencing proceedings pursuant to MCL 769.25a. I. FACTS In the early morning hours of May 17, 1980, defendant and two other people participated in “a brutal and bizarre attack” on an 86-year-old victim in her own home, “where they beat, tortured, and sexually abused her for nearly four hours,” and it led to her death two days later. People v Small, 120 Mich App 442, 445; 327 NW2d 504 (1982).1 Defendant and his codefendant were tried together and, while each of them admitted that they were present, both either implicitly 1 Although the details are not important to the issues raised in this appeal, we have reviewed the record and note that this Court’s description was very mild. -1- or explicitly blamed the other for the assault. Defendant argued that he was not competent to stand trial, but the trial court determined that defendant was competent to stand trial after a competency hearing. Nevertheless, defendant argued to the jury that he was “retarded”2 because he had difficulty reading, had a history of poor academic performance, and was a “follower” to the point of being unable to have the specific intent to commit the charged crimes of his own accord. The jury convicted defendant and his codefendant of first-degree felony murder, and the trial court sentenced each of them to the mandatory term of LWOP. This Court affirmed the convictions in separate appeals. Small, 120 Mich App at 448; People v Gibbs, 120 Mich App 485, 495; 328 NW2d 65 (1982). When defendant first moved for relief from judgment, he argued that he had severe learning problems in school, had an intelligence quotient (IQ) of 61, was borderline mentally handicapped or mildly “retarded,” but, nevertheless, deemed legally sane by the Center for Forensic Psychiatry. He also provided two psychological reports. One stated that his “intellectual functioning appeared to be within the normal range.” The other stated that, although defendant had a history of poor performance in school, defendant was being evasive and dishonest about his involvement in the crime, showed no remorse, and was “extremely vague” about his claim of having “mental problems.” The trial court denied defendant’s motion for relief from judgment. When defendant again moved for relief from judgment, he reiterated that he had been incompetent to stand trial and that his trial violated his rights. The trial court stated that defendant had admitted that he was found competent to stand trial and, because defendant failed to challenge his competency previously, the trial court was not obligated to address that claim. The trial court recognized that recent caselaw held that a mandatory sentence of LWOP was impermissible for juveniles, but it found that caselaw inapplicable to defendant because, at the time, the caselaw did not yet extend the age to offenders who were 18 years old. The trial court found that defendant had not met the requirements for filing a subsequent motion for relief from judgment. This appeal followed. II. STANDARD OF REVIEW “We review a trial court’s decision on a motion for relief from judgment for an abuse of discretion and its findings of facts supporting its decision for clear error.” People v Swain, 288 Mich App 609, 628; 794 NW2