Thirty-five years after her husband was bludgeoned and stabbed to death on a rural Muskegon County road, Barb VanBogelen stood in a courtroom this week and told the man responsible that he should never be free. Jeffrey Abrahamson, who was 19 when he and 16-year-old Amy Lee Black killed 34-year-old Dave VanBogelen in December 1990, had his sentence reduced from life without parole to 40 to 60 years in prison, putting him on track for parole eligibility in about five years.
The resentencing took place at the Muskegon County 60th District Court, where Abrahamson appeared after 35 years in prison and was given credit for 13,087 days already served, according to MLive.com. The reduction stems from a Michigan Supreme Court ruling in 2025 that found mandatory life-without-parole sentences for 19- and 20-year-olds convicted of first-degree murder violate the state constitution, extending protections the court had already given 18-year-olds under its 2022 decision in People v. Parks. The high court grounded its reasoning in scientific consensus that adolescent brain development continues until roughly age 25, according to Michigan Public.
A Robbery That Turned Fatal
On December 7, 1990, Abrahamson and Black encountered VanBogelen at a Muskegon Heights restaurant and lured him to an apartment with plans to rob him, per the station's report. They stole $1,500 in cash from him before he was left for dead on a rural road in Fruitport Township, where he was later found, as detailed by the same account. Both Abrahamson and Black were convicted of first-degree murder and sentenced to life without parole in 1991.
VanBogelen was a husband and father of two young children at the time of his death, leaving Barb VanBogelen to raise them alone after being widowed at age 29. She told the court she had to continue living while remembering why her husband was absent from their lives, per MLive's account of the hearing. She also said she believes the crime required the mind of a sociopath.
Judge Apologizes While Following the Law
14th Circuit Court Judge Annette R. Smedley presided over the resentencing, according to Muskegon County Circuit Court records. MLive reported that Smedley personally opposed any sentence other than life without parole. Abrahamson expressed remorse for his role in VanBogelen's death and read a letter to the court, but the family turned their backs on him as he spoke; Smedley apologized to the VanBogelen family, the outlet reported. Barb VanBogelen told the court Abrahamson should never be free.
The case is not an isolated one. The 2025 ruling applied retroactively, making an estimated 580 to 600 Michigan prisoners who were 19 or 20 at the time of their offenses eligible for new sentencing hearings, according to Michigan Public. State prosecutors were given a 180-day window after the decision to decide whether to re-seek life without parole in exceptional cases.
Co-Defendant's Earlier Release Still Unresolved
Black, who was 16 at the time of the killing, became eligible for a reduced sentence under earlier federal juvenile lifer rulings and was scheduled for parole in September 2022 from the Women's Huron Valley Correctional Facility after receiving a reduced 35-to-60-year sentence, per Legal News. In July 2022, Muskegon County Circuit Judge William Marietti ordered her to pay $1.87 million in restitution to VanBogelen's estate.
That restitution order has become its own source of friction. Following her release, Black was reportedly paying just $25 a month toward the $1.87 million judgment, prompting a Muskegon court review into her post-release finances late last year, as reported by MLive. Barb VanBogelen publicly criticized the payment structure and has vowed to keep fighting for full collection.
Michigan's Broader Shift on Youth Sentencing
The legal path that led to Abrahamson's resentencing traces back to the U.S. Supreme Court's 2012 ruling that mandatory life sentences for juveniles amounted to cruel and unusual punishment. Michigan once housed roughly 360 juvenile lifers, the second-highest total in the country. In 2014, Michigan refused to apply the ruling retroactively, according to the ACLU of Michigan.
Michigan is now one of only three states, alongside Washington and Massachusetts, where state supreme courts have extended constitutional protections against mandatory life-without-parole sentences to emerging adults aged 19 and 20, per the Behind The Bench Newsletter. Washington banned mandatory life-without-parole for offenders under 21 in 2021, while Massachusetts banned all under-21 life-without-parole sentences in 2024. For families like the VanBogelens, those shifts in appellate law have meant revisiting a decades-old loss in court, again and again, as the legal landscape around youthful offenders continues to change.
