People of Michigan v. William Larenzo Shoulders
331672
| Mich. Ct. App. | Jun 27, 2017Background
- Defendant was convicted after a bench trial of OWI causing death (MCL 257.625(4)) and OWI causing serious impairment (MCL 257.625(5)) arising from a February 8, 2015 crash in which one victim died and another was critically injured.
- Evidence: defendant drove at high speed, ran a red light, collided with a truck, then had a secondary collision with the victims’ vehicle; defendant admitted he was intoxicated but testified he fled after being threatened by armed assailants following a fight at a club.
- Trial court credited defendant’s fear of the pursuers, found he was over the legal limit, and convicted him on the OWI offenses.
- Sentencing guidelines produced a recommended minimum range of 43–86 months; the prosecutor sought a low-end guidelines term, but the trial court instead imposed four years’ probation with periodic short jail terms as conditions.
- The People appealed the sentence as of right, arguing Lockridge was wrongly decided and that the trial court erred by departing from the guidelines without substantial and compelling reasons and that probation was disproportionately lenient.
- The Court of Appeals concluded the trial court had discretion under Lockridge to depart from the advisory guidelines but vacated the probationary sentence because the court failed to articulate consideration of the seriousness of the offense and other relevant factors required by the Milbourn proportionality framework.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lockridge can be ignored and guidelines treated as mandatory | Lockridge was wrongly decided; guidelines remain constitutional and mandatory | Lockridge controls; guidelines are advisory | Lockridge binding; guidelines are advisory, so departure without substantial and compelling reasons is permitted |
| Whether the trial court erred by imposing probation well below the guidelines range | Probation is disproportionately lenient and court should have imposed within guidelines absent substantial and compelling reasons | Probation appropriate given defendant’s lack of record, remorse, employment, and rehabilitative potential | Trial court abused discretion by failing to articulate consideration of offense seriousness and proportionality factors; sentence vacated and remanded |
| Proper standard for review of a non-guidelines sentence post-Lockridge | Guidelines mandatory (per plaintiff) or, if advisory, review for reasonableness under appropriate standard | Reasonableness review is required; proportionality (Milbourn) governs in Michigan | Court follows Steanhouse: reasonableness review uses Milbourn proportionality factors; here trial court did not apply them sufficiently |
| Whether defendant’s fear/factual mitigation absolved him of duty of care in sentencing | N/A (plaintiff emphasized offense seriousness) | Defendant’s flight from armed pursuers mitigates culpability and supports leniency | Court accepted the factual finding of fear but held it did not relieve defendant of duty to exercise due care; mitigating facts were considered but insufficiently balanced against offense seriousness in sentencing |
Key Cases Cited
- People v Lockridge, 498 Mich 358 (2015) (Michigan guidelines are advisory; sentencing court may depart without articulating substantial and compelling reasons)
- People v Milbourn, 435 Mich 630 (1990) (established proportionality framework for reviewing sentences)
- People v Steanhouse, 313 Mich App 1 (2015) (held Milbourn proportionality standard governs reasonableness review post-Lockridge)