People of Michigan v. Robert Louis Walden
319 Mich App 344
| Mich. Ct. App. | 2017Background
- Defendant Robert Walden convicted of voluntary manslaughter after claiming self-defense in a killing; sentencing guidelines range was 43–107 months.
- Trial court imposed an upward departure sentence (13 months above guidelines minimum) but gave a terse explanation referencing prior misdemeanors, that defendant was on bond for an aggravated assault, disbelief of the defendant’s testimony, possession/use of a knife, and the victim’s lost future.
- On appeal, the majority upheld the departure as reasonable; Judge Gleicher concurred in part and dissented in part, focusing on procedural and review issues.
- Gleicher emphasizes that under Michigan precedent a departure must be justified by reasoning tied to the principle of proportionality so appellate review is possible.
- Gleicher finds the trial court’s stated reasons either already accounted for in the guidelines, legally improper, or too vague to permit meaningful appellate review, and therefore would remand for resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a trial court must explain grounds for an upward departure in terms of proportionality | Prosecution/majority: departure reasonable given facts (seriousness, prior record, use of a knife, credibility issues) | Walden: trial court failed to provide legally sufficient proportionality-based justification | Gleicher: remand required because trial court’s reasons were either accounted for in guidelines, improper, or unexplained, preventing review |
| Whether facts already scored in the guidelines may justify a departure without additional explanation | Majority: trial court could rely on those facts and implicitly give them greater weight | Walden: departure unjustified if based only on factors already included in guidelines without showing inadequate weight | Held (Gleicher): cannot base departure on characteristics already scored without court finding they were given inadequate/disproportionate weight on record |
| Whether disbelief of defendant’s testimony is a proper ground for departure | Majority: viewed credibility concerns as supporting departure | Walden: such disbelief must be tied to material and willful falsehood or relevant character trait | Held (Gleicher): mere disbelief, without explanation tying it to a relevant character flaw or material falsehood, is improper as a basis for departure |
| Standard of appellate review for departure sentences post-Lockridge | Majority: review for reasonableness and affirmed sentence as reasonable under abuse-of-discretion review | Walden: sentence unreviewable because trial court failed to provide a legally sufficient rationale | Held (Gleicher): appellate court must not substitute its own rationale; absent adequate trial-court reasoning, abuse of discretion and remand for resentencing is required |
Key Cases Cited
- People v. Smith, 482 Mich. 292 (discussing departure-reasoning standard)
- People v. Lockridge, 498 Mich. 358 (2015) (advisory guidelines; review for reasonableness required)
- People v. Milbourn, 435 Mich. 630 (principle of proportionality governs departures)
- People v. Babcock, 469 Mich. 247 (proportionality defines standard for assessing departure reasons)
- People v. Adams, 430 Mich. 679 (credibility-based sentencing considerations require material/willful falsehood link)
- United States v. Martin, 520 F.3d 87 (1st Cir.) (reasonable sentence requires plausible rationale)
- United States v. Boultinghouse, 784 F.3d 1163 (7th Cir.) (appellate courts should not invent justifications for unexplained sentences)