954 N.W.2d 82
Mich.2020Background
- At 15, Davontae Sanford pleaded guilty to four counts of second-degree murder and a felony-firearm charge in 2007; he was credited with 198 days in Wayne County Juvenile Detention and later served 8 years and 61 days in MDOC custody.
- In 2015 a different individual confessed; based on new evidence and the prosecutor’s stipulation the circuit court vacated Sanford’s convictions on June 6, 2016, and he was released June 8, 2016.
- Sanford sued under the Wrongful Imprisonment Compensation Act (WICA), MCL 691.1751 et seq., seeking statutory damages for all time he was confined, including the 198 days in juvenile detention before conviction.
- The Court of Claims awarded compensation for the MDOC confinement but denied recovery for the 198 days in local detention; the Court of Appeals affirmed.
- The Michigan Supreme Court, in lieu of granting leave, held that WICA requires the imprisonment to be “wrongful,” and preconviction detention is not “wrongful” under the statute, so the juvenile-detention days are not compensable; Chief Justice McCormack dissented.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the adverb "wrongfully" in MCL 691.1755(2) modifies both "convicted" and "imprisoned" (i.e., imprisonment must be wrongful to be compensable) | "Wrongfully" should be read broadly to reach the confinement that flowed from the criminal proceeding; imprisonment that results from a wrongful conviction is compensable | "Wrongfully" should not create a new limitation beyond eligibility; compensation tied to statutory eligibility and state correctional-facility confinement | Court: "wrongfully" naturally modifies both verbs; imprisonment must be wrongful to be compensable under WICA |
| Whether preconviction/local juvenile detention (198 days) is compensable under WICA | Sanford: "imprisoned" includes confinement in local/juvenile facilities; all detention for crimes he did not commit is compensable | State: WICA limits compensable imprisonment to time in state correctional facilities after conviction; preconviction detention is not the statutory wrong the Legislature waived sovereign immunity for | Court: Preconviction detention is not "wrongful" under WICA’s text and context; no compensation for the 198 days (affirming Court of Appeals). Dissent: would compensate all detention related to the wrongful conviction, including preconviction juvenile detention. |
Key Cases Cited
- People v. Spann, 469 Mich. 904 (2003) (interpreting "term of imprisonment" to include non-MDOC confinement; supports broader meaning of "imprisonment")
- Brackett v. Focus Hope, 482 Mich. 269 (2008) (undefined statutory terms given plain ordinary meaning; dictionary may be consulted)
- Pohutski v. City of Allen Park, 465 Mich. 675 (2002) (state sovereign immunity principles; waiver of immunity construed strictly)
- Russello v. United States, 464 U.S. 16 (1983) (canon that inclusion of language in one statutory provision and exclusion in another is intentional)