Loren Robinson v. Jeffrey Woods, 901 F.3d 710

Loren Robinson was convicted in Michigan state court of extortion, delivery of a controlled substance, unlawful imprisonment, and aggravated assault; a PSIR scored offense- and offender-variables that increased his guideline minimums.
Michigan trial judge accepted the PSIR scores and imposed minimum sentences well above the low end of the recommended ranges; sentences were mandatory at the time (judge could depart only for "substantial and compelling" reasons).
Michigan Court of Appeals affirmed, relying on state precedent holding Blakely inapplicable to Michigan’s indeterminate sentencing scheme; Michigan Supreme Court denied leave.
Robinson filed a 28 U.S.C. § 2254 habeas petition claiming Sixth Amendment error because judge-found facts increased his mandatory minimums; the federal district court denied relief and declined a COA.
Sixth Circuit granted a COA limited to the Sixth Amendment sentencing issue and reversed the district court, holding Alleyne controlled and Michigan’s mandatory guidelines (as applied) violated the Sixth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether use of judge-found facts to score Michigan guideline variables that raised mandatory minimums violated the Sixth Amendment	Robinson: Alleyne requires any fact that increases a mandatory minimum be submitted to a jury or admitted; judge-found OV/PRV scoring here violated the Sixth Amendment	State: Michigan’s scheme is "indeterminate" (minimum = parole-eligibility), thus Blakely/Apprendi line doesn’t bar judicial factfinding; Alleyne not retroactive on collateral review	Held for Robinson: Alleyne applies to mandatory minimums and made Michigan’s then-mandatory guidelines unconstitutional as applied; habeas relief granted limited to sentencing

Alleyne v. United States, 570 U.S. 99 (mandatory-minimum increasing facts are elements requiring jury determination)
Apprendi v. New Jersey, 530 U.S. 466 (facts increasing prescribed penalty range must be found by jury)
Blakely v. Washington, 542 U.S. 296 (distinguishing determinate and indeterminate systems in Sixth Amendment context)
Harris v. United States, 536 U.S. 545 (overruled in part by Alleyne; previously allowed judge-found facts to increase mandatory minimums)
McMillan v. Pennsylvania, 477 U.S. 79 (prior precedent allowing judicial factfinding on sentencing, limited by Alleyne)
Griffith v. Kentucky, 479 U.S. 314 (new rules apply to cases pending on direct review)
United States v. Booker, 543 U.S. 220 (applying Sixth Amendment sentencing principles to cases on direct review)
People v. Lockridge, 870 N.W.2d 502 (Mich. 2015) (Michigan Supreme Court holding Alleyne renders mandatory guidelines unconstitutional)