People of Michigan v. Ronald Parker Wilson, 334025

Ronald Wilson was convicted by a jury of two counts of assault with intent to do great bodily harm less than murder (MCL 750.84) and one count of felony-firearm (MCL 750.227b) for a shooting after an altercation following a party bus. He shot two victims; six spent shells were recovered.
On initial appeal this Court affirmed convictions but vacated the sentences and remanded because the trial court incorrectly scored OV 14 (role in offense), affecting the guidelines range.
Corrected scoring reduced Wilson’s advisory guidelines range from 29–57 months to 19–38 months for the assault counts.
On remand the trial court resentenced Wilson to the same terms it had originally imposed: concurrent 57 months–10 years for each assault count, consecutive two years for felony-firearm — an upward departure from the corrected guidelines.
The trial court primarily relied on the seriousness of the offense to justify the upward departure but provided only brief explanation; the Court of Appeals found the justification insufficient for meaningful appellate review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the resentencing upward departure was reasonable	People argued the court could reimpose the same sentence if it would have done so without being bound by advisory guidelines	Wilson argued the 57–120 month assault sentences are disproportionate to the corrected guidelines (19–38 months) and therefore unreasonable	Vacated and remanded: trial court’s brief reliance on "seriousness" was insufficient; trial court must articulate why the sentence is more proportionate than a lower one
Whether the trial court needed to explain its departure to permit appellate review	People said remand required only a determination whether court would have given same sentence absent mandatory guidelines	Wilson said the court must justify the sentence with reasons showing proportionality under Milbourn/Lockridge	Held: court must justify the sentence with an explanation of why it is more proportionate than alternatives to facilitate review

People v Steanhouse, 500 Mich 453 (2017) (sentences reviewed for reasonableness; court must justify sentence to facilitate appellate review)
People v Lockridge, 498 Mich 358 (2015) (made Michigan sentencing guidelines advisory; review limited to reasonableness)
People v Milbourn, 435 Mich 630 (1990) (principle of proportionality: sentence must account for nature of offense and offender)
People v Walden, 319 Mich App 344 (2017) (discusses Lockridge’s effect on appellate review and proportionality analysis)
People v Smith, 482 Mich 292 (2008) (trial court should explain why imposed sentence is more proportionate than alternatives)