People of Michigan v. Anthony Mark Rice, 329502

Defendant Anthony Rice pleaded guilty as a fourth-offense habitual offender to operating/maintaining a methamphetamine lab and a location-enhanced count; sentenced below guidelines to concurrent terms of 48 months–35 years.
Rice had admitted buying chemicals to manufacture methamphetamine in an apartment building pursuant to a Cobbs agreement; trial court had indicated it would sentence at the bottom of the guidelines range.
Sentencing guidelines initially scored Rice’s recommended range as 72–240 months; the scoring did not rely on judicial fact-finding.
At sentencing Rice presented evidence of positive institutional conduct (work, rehabilitation, no misconduct), and the trial court departed downward based on those rehabilitative factors and concerns about self-poisoning.
The prosecutor argued Lockridge did not apply because Rice’s sentence did not depend on judicial fact-finding; the trial court held Lockridge made the guidelines advisory in all cases and treated the guidelines as advisory.
The prosecution appealed; the Court of Appeals affirmed, holding Lockridge renders MCL 769.34(2) and (3) advisory without limiting its effect to cases involving judicial fact-finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lockridge's holding that Michigan's sentencing guidelines are unconstitutional when based on judge-found facts applies only when judicial fact-finding actually occurred	Lockridge applies only when a sentence depends on judicial fact-finding; where guidelines scoring did not rely on judge-found facts, the guidelines remain mandatory	Lockridge's language rendered the guidelines advisory generally; courts may treat the guidelines as advisory even when no judicial fact-finding occurred	Court held Lockridge makes the legislative guidelines advisory in all cases, regardless of whether judicial fact-finding occurred

People v Lockridge, 498 Mich 358; 870 NW2d 502 (Mich. 2015) (held Michigan sentencing guidelines unconstitutional as mandatory when based on judge-found facts and severed statutory mandate, making guidelines advisory)
Apprendi v New Jersey, 530 U.S. 466 (2000) (holds that any fact that increases penalty beyond prescribed statutory maximum must be submitted to jury and proved beyond a reasonable doubt)
Alleyne v United States, 570 U.S. 99 (2013) (extends Apprendi to facts that increase mandatory minimum sentences)
People v Cobbs, 443 Mich 276; 505 NW2d 208 (1993) (procedure for plea withdrawal when court exceeds preliminary sentence evaluation)
People v Strickland, 293 Mich App 393; 810 NW2d 660 (2011) (state appellate court observes obligation to follow Michigan Supreme Court decisions)